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Toilet paper dispensers

Mr. Inspector

SAWHORSE
Joined
Nov 28, 2009
Messages
4,076
Location
Poconos/eastern PA
There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.

So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?
 
There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.

So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?

Love your PA questions
 
it also has a requirement for distance from the front of the bowl

This was true in the ICC/ANSI 117.1 2003 but not in the 2009 that I am using now. The code requires the toilet paper dispenser to be a certain distance from the rear wall only if it is mounted above or below the grab bar:

604.7 Toilet dispensers shall comply with section 309.4. Where the dispenser is located above the grab bar, the outlet of the dispenser shall be located withing 24" min. and 36" max. from the rear wall. Where the dispenser is located below the grab bar the outlet of the dispenser shall be located within an area 24" min. and 42" max. from the rear wall. The outlet of the dispenser shall be located 18" min. and 48" max. above the floor. Dispensers shall not be the type that control delivery, or do not allow continuous paper flow.

Dispensers are required to also comply with ADA Section 604.7, which addresses the location requirements in general.

Interesting but don't enforce ADA and don't care or know it.
 
Rick, are you an architect, inspector or .... ?
Makes no difference, contrary to the code, your state laws must at a minimum be equal to but no less than the 2010 ADASAD.
As to wall side mounted vs the open side, if mtd. on the open side it would exceed reach ranges, if post mtd. it would obstruct floor space.
What is the reason for the initial question?
 
There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.

So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?

Rick, there was a similar discussion in another thread - - this seems like a weird loophole, but I think you are correct. ADAS and the code only seem to address 2 of the 3 dimensions for T.P. dispensers: vertical height above finish floor, and horizontal distance in front of the bowl rim. It does not address the side-to-side distance from the centerline of the toilet; probably most everyone assumes you intend to mount it on the closest side wall.

However, ADAS 604.3.2 allows dispensers and many other components to "overlap" the required maneuvering clearance around the accessible toilet:
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
No other fixtures or obstructions shall be located within the required water closet clearance.

In theory, you could have a T.P. floor stand centered 7" directly in front of the rim, making transfer from a wheelchair impossible, and yet it would still comply with the letter-of-the-law.
demetra-floor-standing-toilet-paper-holder-kitchens-bathrooms-throughout-stand-alone-toilet-paper-holder-prepare-9.png


Furthermore, ADAS 604.3.2 doesn't limit the purpose of the "dispenser". Again, in theory, it could be a soda vending machine, dispensing cans of coke: it's a "dispenser", allowed to encroach.

Lastly, I don't think there is anything in the building or plumbing codes that compel either the toilet paper or the toilet paper dispenser to be provided at all! Bring your own corn husk.
 
Talk about opening a bag of worms? Placing it on the wide side would not be defensible as it also does not meet any measurable standard of practice.
Show me a standard of practice reference where you have seen it located otherwise.
 
ADAguy, I appreciate the concern for standard of practice. But the original post wasn't about standard of practice, it was about the "requirement" of what the "code only specifies".
In this case, the code - as written - allows for a design where you meet the letter of the law, but not the spirit of its intent (a usable toilet for persons with disabilities).

My larger point about "loopholes" is probably the same as what I think you're saying - that code alone is insufficient to create a truly usable building. The minimum requirements of the code alone can only identify the legal boundary beyond which is "not compliant"; it can't force the central goal of what is the most appropriate design solution.

Nevertheless, the original question was focused on what the code actually allows, not on what was the appropriate design standard of practice to meet the spirit of the code.
 
May be an instance where the code language does not specifically require the location but surely Ice would never allow that as well as any other inspector I could imagine. A request for code language to support the inspectors requirement that the TP dispenser be relocated would fall on deaf ears and the GC would relocate.
 
JPohling, of course we are merely playing out a hypothetical here, and most GC's would pick and choose their battles with an inspector over something less mundane than a TP roll.
But remember, the building code does not require ANY toilet paper, nor a toilet paper dispenser.

Marginally-related story: In yesterday's NY Times, there was an article about the disappearing job of bathroom attendants. There was a time when many toilets were pay toilets, and many the "dispensers" of toilet room consumables (towels, soaps, etc.) were live attendants.
https://www.nytimes.com/2019/05/08/style/bathroom-attendants.html

Also, some toilets these days come with built-in washlets (bidets) and dryers, claiming to make TP obsolete.
Point is, the code has always allowed for scenarios where there would be no toilet paper, or paper towels, or dryers. So if the toilet paper floor rack shown in the earlier post was removed from the room during your inspection, what would be your legal mechanism to deny approval of the construction? Yes, as an inspector you could make their life miserable in other ways, and you could delay them with deaf ears as long as possible, but it doesn't change what the code says or allows.
 
The key code wording with regards to your question is : "If provided". If you do, your comment may be seen as valid as the dispenser could then be hung from a sky hook on the wide side as long as it met the 7- 9" and the reach ranges. Try to imagine that?
 
Rick, there was a similar discussion in another thread - - this seems like a weird loophole, but I think you are correct. ADAS and the code only seem to address 2 of the 3 dimensions for T.P. dispensers: vertical height above finish floor, and horizontal distance in front of the bowl rim. It does not address the side-to-side distance from the centerline of the toilet; probably most everyone assumes you intend to mount it on the closest side wall.

However, ADAS 604.3.2 allows dispensers and many other components to "overlap" the required maneuvering clearance around the accessible toilet:
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
No other fixtures or obstructions shall be located within the required water closet clearance.

In theory, you could have a T.P. floor stand centered 7" directly in front of the rim, making transfer from a wheelchair impossible, and yet it would still comply with the letter-of-the-law.
demetra-floor-standing-toilet-paper-holder-kitchens-bathrooms-throughout-stand-alone-toilet-paper-holder-prepare-9.png


Furthermore, ADAS 604.3.2 doesn't limit the purpose of the "dispenser". Again, in theory, it could be a soda vending machine, dispensing cans of coke: it's a "dispenser", allowed to encroach.

Lastly, I don't think there is anything in the building or plumbing codes that compel either the toilet paper or the toilet paper dispenser to be provided at all! Bring your own corn husk.
Interferes with clear space?
 
mark handler: "Interferes with clear space?"
Quoting the code, which uses the term "overlap" in lieu of "interferes":
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.

Show me in the code where I'm wrong!
 
The key code wording with regards to your question is : "If provided". If you do, your comment may be seen as valid as the dispenser could then be hung from a sky hook on the wide side as long as it met the 7- 9" and the reach ranges. Try to imagine that?

Yes, the sky hook is allowable by code and it could be 20' away from the toilet on the wide side, as long as it meets the 7-9" in front of the toilet, the allowable dispenser height per 604.7.

I'm not saying you have to like it. I don't like it either. I'm only saying the code allows it. Show me where I'm wrong.

Likewise regarding the word "shall": you did not provide a code reference. Please provide one, otherwise I'm going to assume you're looking at 11B-604.7, "Toilet paper dispensers shall comply with...".
This sentence does not say you shall provide a toilet paper dispenser.
It says that toilet paper dispensers shall comply with the dimensional requirements of 11B-604.7.

Analogy: the state says my car shall comply with the requirements of the Dept.of Motor Vehicles. But my state does not require me to own a car.

Show me in the building code, plumbing code, etc. where it requires toilet paper, or a toilet paper dispenser, to be provided. The only place I've found it is in health codes, such as for food retail facilities :
114250. Clean toilet rooms in good repair shall be provided and conveniently located and accessible for use by employees during all hours of operation. The number of toilet facilities required shall be in accordance with applicable local building and plumbing ordinances. Toilet tissue shall be provided in a permanently installed dispenser at each toilet.

Notice that the health code had to go out of its way to mention the T.P. (and it's only required for employees!) because the building and plumbing codes do not address it.

P.S. I'm not trying to troll anyone here. I'm trying to point out the limitations of the building codes in addressing real-world conditions.
 
Last edited:
mark handler: "Interferes with clear space?"
Quoting the code, which uses the term "overlap" in lieu of "interferes":
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.

Show me in the code where I'm wrong!
The Intent
 
mark handler: "Interferes with clear space?"
Quoting the code, which uses the term "overlap" in lieu of "interferes":
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.

Show me in the code where I'm wrong!

Had an inspection of an accessible toilet room that had a 6' high shelf unit in the clear space between the toilet and the sink. It was sitting on the floor partly blocking the rear grab bar. I need to quote sections of the code when I find something wrong. The only thing the code says about this is above. So I had to let it go and approve it.
 
It is a moveable object but the owner has a maintenance requirement as to the clear floor space. If it obstructs, then "move it"
It may move back but you have addressed it.
 
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