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1, single user, unisex toilet room in coffee shop, per 2021 IBC

taylorrennert

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Feb 24, 2025
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Kaua'i, HI
Hi,

I have a client, who has (1) single-user, unisex/ gender neutral, accessible bathroom in a coffee shop. 2021 IBC applies, with their changes regarding these single user restrooms.

We have 63 total occupants, and our calculations per table 2902.1 and 2902.1.1 result in a required # of toilets @ 0.893. Mostly using the restaurant rate @ 1 toilet per 75.

2021 IBC, 2902.2, exception #5 states: "Separate facilities shall not be required to be designated by sex where single-user toilets rooms are provided in accordance with Section 2902.1.2."

Our plan reviewer is saying that this exception only makes bathrooms unisex, but doesn't take away the "separation requirement" and that we still need 2 a bathrooms. I think he is reading the code erroneously/ illogically.

Exception #5 is written a little confusing, but but, by the code allowing to make it unisex, it makes any separation requirement null, because the separation is only required by sex, and if there's no sex designation, therefore no separation. I feel confident on this, but looking for support from other professionals to back it up, thanks!
 
I'm inclined to agree with the plans examiner. You have 63 occupants = 32 men and 32 women (rounded up). If you apply that to Table 2902.1, you get 2 water closets - 1 for men and 1 for women.

I read 2902.2 exception 5 as essentially "you need to provide the fixtures per 2902.1, but if the fixtures are in unisex rooms, they don't need to be designated as men or women's". Basically, that exception doesn't reduce the fixture count, just makes it so you don't need to identify a toilet room for a specific sex.

The exceptions you are probably thinking this is are exceptions 1 through 4. If you met any those exceptions, only one toilet room would be required. Exceptions 5 and 6 do not reduce the fixture count.
 
I'm inclined to agree with the plans examiner. You have 63 occupants = 32 men and 32 women (rounded up). If you apply that to the table, you get 2 water closets - 1 for men and 1 for women.

I read 2902.2 exception 5 as essentially "you need to provide the fixtures per 2902.1, but if the fixtures are in unisex rooms, they don't need to be designated as men or women's". Basically, that exception doesn't reduce the fixture count, just makes it so you don't need to identify a toilet room for a specific sex.

The exceptions you are thinking this is is exceptions 1 through 4. If you met those exceptions, only one toilet room would be required.
Thanks for your input- Per 2902.1 exception #3, under "fixture calculations" , it states: "Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 2902.1.2."

So, in the instance of single user restrooms, you do not need to separate by men and women for the calculation. My calculations have 61 occupants @ 1 per 75 = 0.813 WC. Then 2 occupants (men and women combined) @ 1 per 25= 0.080, resulting in a total of 0.893 WC.
 
Thanks for your input- Per 2902.1 exception #3, under "fixture calculations" , it states: "Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 2902.1.2."

So, in the instance of single user restrooms, you do not need to separate by men and women for the calculation. My calculations have 61 occupants @ 1 per 75 = 0.813 WC. Then 2 occupants (men and women combined) @ 1 per 25= 0.080, resulting in a total of 0.893 WC.
Well crap. Got my California requirements mixed up with this I guess. My bad.
 
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Exception #5 to IBC Section 2902.2 does not eliminate the need for separate facilities per Section 2902.2; it merely states that they do not need to be identified by sex--both can be identified as unisex.

Therefore, since separate facilities are required, the calculations must be performed separately for each sex. Thus, a minimum of two restrooms are required.
 
Exception #5 to IBC Section 2902.2 does not eliminate the need for separate facilities per Section 2902.2; it merely states that they do not need to be identified by sex--both can be identified as unisex.

Therefore, since separate facilities are required, the calculations must be performed separately for each sex. Thus, a minimum of two restrooms are required.
This does not seem logical. Because, by 2902.2, exception #5, you are able to eliminate the "designation by sex", and 2902.2 states " separate facilities shall be provided for each sex". Then logic would conclude that if there is no "designation by sex", then there is also no "separate facilities".
 
This does not seem logical. Because, by 2902.2, exception #5, you are able to eliminate the "designation by sex", and 2902.2 states " separate facilities shall be provided for each sex". Then logic would conclude that if there is no "designation by sex", then there is also no "separate facilities".

The exception applies to the designation, not the the calculation. You need one water closet for males and one for females. They can be in two toilet rooms, either designated one male and one female, or both designated unisex. The IBC Commentary language for exception #5 confirms this.
 
The exception applies to the designation, not the the calculation. You need one water closet for males and one for females. They can be in two toilet rooms, either designated one male and one female, or both designated unisex. The IBC Commentary language for exception #5 confirms this.
There is also the exception under the calculations portion , 2902.1.1, reading "Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 2902.1.2.". So, that is what tells you that you don't need to use the male/ female WC separately when using single-user restrooms.

Keep in mind, this is all new to 2021 and newer editions.
 
The exception applies to the designation, not the the calculation. You need one water closet for males and one for females. They can be in two toilet rooms, either designated one male and one female, or both designated unisex. The IBC Commentary language for exception #5 confirms this.
Is there a section that allows a single-user toilet room to replace the 2 separate water closets if the OL is low enough?

I ask because California / UPC has a exception that allows a business or mercantile occupancy with an OL less than 50 (or other occupancies with the OL less than 10) to have a single unisex toilet room instead of two separate rooms, effectively removing one water closet and lav from the requirements.

Just curious if IBC has something similar.
 
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Im looking at 2022 CBC and this section looks the same as 2021 IBC

In your mentioned scenario, for business , at 50 occupants, and a fixture ratio of 1:25, you'd need 2 restrooms, either M/F, or unisex.

Is there a section that allows a single-user toilet room to replace the 2 separate water closets if the OL is low enough?

I ask because California / UPC has a exception that allows a business or mercantile occupancy with an OL less than 50 (or other occupancies with the OL less than 10) to have a single unisex toilet room instead of two separate rooms, effectively removing one water closet and lav from the requirements.

Just curious if IBC has something similar.
 
Sorry for going off topic, but 63 occupant for a coffee shop is high. Its common for this type of establishment to keep the occupant load under 50 so it can be classified as a Business Occupancy. At 63 occupants you are an assembly occupancy which could potentially add cost to the project.
 
Don't forget this little honey that I think is being overlooked:

[P]​

To determine the occupant load of each sex, the total occupant load shall be divided in half. To determine the required number of fixtures, the fixture ratio or ratios for each fixture type shall be applied to the occupant load of each sex in accordance with Table 2902.1. Fractional numbers resulting from applying the fixture ratios of Table 2902.1 shall be rounded up to the next whole number. For calculations involving multiple occupancies, such fractional numbers for each occupancy shall first be summed and then rounded up to the next whole number.

Exceptions:

  1. 1.The total occupant load shall not be required to be divided in half where approved statistical data indicates a distribution of the sexes of other than 50 percent of each sex.
  2. 2.Where multiple-user facilities are designed to serve all genders, the minimum fixture count shall be calculated 100 percent, based on total occupant load. In such multiple-user user facilities, each fixture type shall be in accordance with ICC A117.1 and each urinal that is provided shall be located in a stall.
  3. 3.Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 2902.1.2.
 
Sorry for going off topic, but 63 occupant for a coffee shop is high. Its common for this type of establishment to keep the occupant load under 50 so it can be classified as a Business Occupancy. At 63 occupants you are an assembly occupancy which could potentially add cost to the project.
And then the fixture count numbers would change...
 
Im looking at 2022 CBC and this section looks the same as 2021 IBC

In your mentioned scenario, for business , at 50 occupants, and a fixture ratio of 1:25, you'd need 2 restrooms, either M/F, or unisex.
California doesn't adopt ch 29 of the IBC. We use the UPC chapter 4 for our plumbing fixture calculations.
1740501705564.png

Edit: sounds like IBC doesn't have a similar exception then. Oh well. Though I'd ask just in case :)
 
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Don't forget this little honey that I think is being overlooked:

[P]​

To determine the occupant load of each sex, the total occupant load shall be divided in half. To determine the required number of fixtures, the fixture ratio or ratios for each fixture type shall be applied to the occupant load of each sex in accordance with Table 2902.1. Fractional numbers resulting from applying the fixture ratios of Table 2902.1 shall be rounded up to the next whole number. For calculations involving multiple occupancies, such fractional numbers for each occupancy shall first be summed and then rounded up to the next whole number.

Exceptions:

  1. 1.The total occupant load shall not be required to be divided in half where approved statistical data indicates a distribution of the sexes of other than 50 percent of each sex.
  2. 2.Where multiple-user facilities are designed to serve all genders, the minimum fixture count shall be calculated 100 percent, based on total occupant load. In such multiple-user user facilities, each fixture type shall be in accordance with ICC A117.1 and each urinal that is provided shall be located in a stall.
  3. 3.Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 2902.1.2.
Yep, I am thinking #3 is the key to this question. Essentially, this, and the intent of the 2021 changes for this, allow for the designer to opt to use single-user water closets, in all circumstances. Thanks
 
Sorry for going off topic, but 63 occupant for a coffee shop is high. Its common for this type of establishment to keep the occupant load under 50 so it can be classified as a Business Occupancy. At 63 occupants you are an assembly occupancy which could potentially add cost to the project.
It is a bit larger of a coffee shop... meets all the requirements for an A occupancy, 2 exits, etc. Thanks for your comment
 
Yep, I am thinking #3 is the key to this question. Essentially, this, and the intent of the 2021 changes for this, allow for the designer to opt to use single-user water closets, in all circumstances. Thanks
How would you handle something like, say, a Casino? Men and women have a different requirements in Table 2902.1. Using multiple unisex toilet rooms, it seem that you could reduce or increase the water closet requirements substantially depending on how you calculate a unisex OL.
 
How would you handle something like, say, a Casino? Men and women have a different requirements in Table 2902.1. Using multiple unisex toilet rooms, it seem that you could reduce or increase the water closet requirements substantially depending on how you calculate a unisex OL.
Without actually thinking or looking it up....Worst case...I think this is only a thing when you are arguing at the bottom of the numbers....
 
I now actually have confirmation from senior technical staff @ the ICC, that indeed the (1) single user restroom is sufficient for a coffee shop with 63 occupants, under the 2021 code. The main reason this is compliant, is because of 2902.1.1, exception #3, which allows you to run the fixture calcs without dividing up by sex. Interestingly, though, this exception is removed in 2024 IBC, so in that edition, you'd need 2 restrooms.
 
Without actually thinking or looking it up....Worst case...I think this is only a thing when you are arguing at the bottom of the numbers....
Interesting question, and I don't think 21 code addresses it. Most conservatively, I guess you could go with the higher rate. But, that would likely result in an overall higher # of fixtures required. So, perhaps in that instance, it would make most sense to do the calcs for M/F split, and then you can still opt for the single-user restrooms.
 
This is kind of sort of how they fixed it...And deleting Ex. 3....

[P]​

To determine the occupant load of each sex, the total occupant load shall be divided in half. To determine the required number of fixtures, the fixture ratio or ratios for each fixture type shall be applied to the occupant load of each sex in accordance with Table 2902.1. Fractional numbers resulting from applying the fixture ratios of Table 2902.1 shall be rounded up to the next whole number. For calculations involving multiple occupancies, such fractional numbers for each occupancy shall first be summed and then rounded up to the next whole number.

Exceptions:

  1. 1.The total occupant load shall not be required to be divided in half where approved statistical data indicates a distribution of the sexes of other than 50 percent of each sex.
  2. 2.Where multiple-user facilities are designed to serve all genders, the minimum fixture count shall be calculated 100 percent, based on total occupant load. In such multiple-user user facilities, each fixture type shall be in accordance with ICC A117.1 .

[P]​

The plumbing fixtures located in single-user toilet facilities and single-user rooms, including family or assisted-use toilet facilities and bathing rooms, shall contribute toward the total number of required plumbing fixtures for a building or tenant space. The number of fixtures in single-user toilet facilities, single-user bathing rooms and family or assisted-use toilet facilities shall be deducted proportionately from the required gender ratios of Table 2902.1. Single-user toilet facilities and bathing rooms, and family or assisted-use toilet facilities and bathing rooms shall be identified as being available for use by all persons regardless of their sex.

The total number of fixtures shall be based on the required number of separate facilities or based on the aggregate of any combination of single-user or separate facilities.
INSIGHTS (1)

[P]​

Where two or more toilet facilities are provided for each sex, the required number of lavatories shall be distributed proportionately to the required number of male- and female-designated water closets.
 
403.1.1 / 2902.1.1, exception #3 says that Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 403.1.2

But 403.1.2 says ……The total number of fixtures shall be permitted to be based on the required number of separate facilities or based on the aggregate of any combination of single-user or separate facilities.

They seem to contradict one another…..
 
403.1.1 / 2902.1.1, exception #3 says that Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 403.1.2

But 403.1.2 says ……The total number of fixtures shall be permitted to be based on the required number of separate facilities or based on the aggregate of any combination of single-user or separate facilities.

They seem to contradict one another…..
A "mistake"? In the code?...No?
 
A "mistake"? In the code?...No?
I wouldn't say that's a mistake. "Separate facilities" are just not "unisex facilities". If you provide unisex facilities, then you don't need separate sex-specific facilities. You still need to provide the plumbing fixtures as if there were separate facilities, but you just don't need to call them separate facilities.

Example: you need 6 water closets - 2 men, 4 women. You can either have two separate facilities (i.e., a men's restroom with 2 WC and a women's restroom with 4 WC) or you can provide 6 unisex water closets (i.e., 6 single-user toilet rooms or 1 shared all-gender restroom with 6 WC). At least, that's the way I've been told to do this by a few plan checkers...
 
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