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Unisex bathroom in office space.

Just the implication that they are accessible is not a requirement; if there is nothing that directly says they are required to be accessible then they are not required to be accessible. There are other instances where areas are required to be on an accessible route, but the area itself is not required to be accessible (e.g., employee work areas).

I don't believe it is the intent for the IBC to be more restrictive than the ADA. The ADA Standards, as I mentioned above, do not use the term "family/assisted-use" toilet rooms, but instead use single-user and unisex toilet rooms, which means single-use or family. Per the ADA Standards, when multiple single-user (i.e., unisex) restrooms are clustered, only 50% are required to be accessible--this is nearly identical to what the IBC requires. Thus, the intent of the IBC language is to codify the ADA Standards within the building code.
 
Intent? yes it is but achieving concurrence (as in safe harbor) continues to be an issue.
 
I had this counterpoint all prepared when I discovered a change to the 2021 IBC that weakened that counterpoint significantly. So, I contacted the five proponents (of which included a member of the US Access Board and a member of the United Spinal Association) of that change and asked them specifically if their intent was to include family or assisted-use toilet rooms in the 1109.2 Exception 3, thus allowing one of the two clustered family or assisted-use toilet rooms to be non-accessible. The response I received from them was "affirmative." This should clear things up :)
 
ADAguy said:
Does that mean it is equal to but no less than ADA minimums? Does DOJ agree?
Click to expand...

I think you'll find the answer to that will be yes, but I am not the source to confirm that. The proponent I spoke to referred much to the ADA Standard, and has/had the knowledge and experience in assisting with the revisions to that standard back in 2010. Her current position title is Director, Accessibility Codes and Standards.
 
See AccessibilityOnline webinar archives for 2/6/2020 Using the ADA and ABA Standards Series: Scoping. Clustered restrooms was discussed yesterday.
Note: this is an excellent "free" source for ADA issues.
 
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