A117.1-2017 - Type A Dwelling - Toilet/Lavatory overlap

[tcoon]

Hi All,

I have a Type A dwelling unit where my accessible bathroom provides the toilet clearance using the lavatory overlap exception, so 60" wide X 66" deep. My lavatory has a vanity beneath it, with a removable front, so the lavatory can be accessible, but the side panels of the vanity remain. Would this comply with the exception requirements? Or would the remaining side panel, adjacent to the toilet, have to provide knee and toe clearance (like a bracket)?


Thanks for any input,
T

 

[Yankee Chronicler]

The entire under-sink cabinetry has to be removable.

A117.1-2017:

1103.11.2.4.2 Clearance width. Clearance around
the water closet shall be 60 inches (1525 mm) minimum
in width, measured perpendicular from the
side wall.

1103.11.2.2 Lavatory. Lavatories shall comply with
Section 606.
Exception: Cabinetry shall be permitted under the
lavatory, provided the following criteria are met:
1. The cabinetry can be removed without
removal or replacement of the lavatory;
2. The floor finish extends under the cabinetry;
and
3. The walls behind and surrounding the cabinetry
are finished.

It doesn't say the front of the vanity. It says "The cabinetry can be removed.." Leaving the side panel obviously doesn't leave the 60-inch maneuvering clearance required for the water closet unobstructed.

 

[Yikes]

It is not uncommon to have side panels remain that comply with knee and toe clearance, and to have it be accepted as reasonably equivalent to the allowable dimensions of the lavatory itself.
Here's a photo from a presentation by LA Housing Department's Neutral Accessibility Consultant:

 

[Yankee Chronicler]

It is not uncommon to have side panels remain that comply with knee and toe clearance, and to have it be accepted as reasonably equivalent to the allowable dimensions of the lavatory itself.
Here's a photo from a presentation by LA Housing Department's Neutral Accessibility Consultant:

View attachment 12115

Note that this is an exception, approved "on a case-by-case basis." It is not the code or the ADA or UFAS.

 

[Yikes]

I talked to the NAC about this during the seminar - - specifically, why does it need to be on a "case-by case basis"?

The ADA Standards shows an illustration that shows a countertop only - - it does not show a side bracket:


However, ADA 604.3.2 does allow "associated... shelves" as well as other items within the clear floor space for the toilet. Shelves typically have support brackets, so the NAC would allow the vanity countertop to have a bracket, given that the countertop functions as a type of shelf adjacent to the toilet, which complies with 604.3.2.

What is not allowed is "cabinetry". A cabinet is a type of enclosed storage, which is not explicitly allowed in 604.3.2 and is thus considered an obstruction. So the NAC wants to confirm the encroaching bracket space isn't also being used for storage, such as the red drawer shown below:


Thus the NAC reviews the designs on a case-by-case basis.

 

[Yankee Chronicler]

Even allowing a bracket such as shown within the maneuvering space for the water closet relies on the revolving cones model, which has never been part of the code but which has been used by some jurisdictions "on a case-by-case basis" to allow modifications. The revolving cone model basically takes the knee and toe clearance dimensions for under sinks and spins it into a 360-degree circular solid, on the theory that if it works under a sink, it works anywhere.

https://www.revitcity.com/object_docs/4390.jpg

But there's nothing in the ADA, UFAS, or A117.1 that says this can be applied to the clear space for a water closet. Where it is allowed, it is by exception or modification granted by the AHJ.

 

[classicT]

The revolving cone model

 

[Yikes]

As mentioned in post #5, the vanity countertop does not rely on the revolving cone model for code compliance; it relies on the vanity countertop being considered either as part of the lavatory, which is allowable encroachment in residential dwelling units, and/or as an allowable associated shelf.

 

[MADrkTEK]

Edit: I realized after posting this question was not related to commercial use.. my comment below is not fully applicable....

ICC A11.1-2017

604.3.3 Clearance Overlap​

The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, paper dispensers, sanitary napkin receptacles, coat hooks, shelves, accessible routes, clear floor space at other fixtures and the turning space. No other fixtures or obstructions shall be within the required water closet clearance.


We have had a few instances over the years where even having a paper (hand) towel dispenser or hand air dryer on a wall along the toilet clearance area was flagged.

 

[Paul Sweet]

I hope you don't have to suspend the front of the counter from the ceiling by a cable, which would be the only way you could meet the Guide to ADA Standards drawing if somebody took it literally.

 

[Yikes]

Edit: I realized after posting this question was not related to commercial use.. my comment below is not fully applicable....

ICC A11.1-2017

604.3.3 Clearance Overlap​

The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, paper dispensers, sanitary napkin receptacles, coat hooks, shelves, accessible routes, clear floor space at other fixtures and the turning space. No other fixtures or obstructions shall be within the required water closet clearance.


We have had a few instances over the years where even having a paper (hand) towel dispenser or hand air dryer on a wall along the toilet clearance area was flagged.

As discussed in some older threads, IMO a paper (hand) towel dispenser IS an allowable overlap.

Confusion seems to arise as to whether the word "associated" applies only to grab bars, or to all the other words that follow, e.g. "associated paper dispensers". Under this logic, hand towel paper dispensers are not allowed, because you don't need paper hand towels to use a water closet.
But if you take that stance, then you must also pair the word "associated" with other items on the list, like this:

• "Associated coat hook"
• "Associated shelves"

No one really NEEDS a coat hook or a shelf in order to successfully use a water closet, and yet there is some scenario in the code under which these can be considered "associated". Now, consider that there are plenty of health codes that require washing of hands (by food service employees) after using a toilet. Therefore, if coat hooks and shelves can be "associated" with water closet use, then surely paper hand towels can be even more associated with water closet use, and are therefore an allowable encroachment.

 

[Yankee Chronicler]

View attachment 12124

That's the one. Thanks for finding a good illustrative diagram -- I used to have one, a long time ago, but I have no idea where to find it.

As mentioned in post #5, the vanity countertop does not rely on the revolving cone model for code compliance; it relies on the vanity countertop being considered either as part of the lavatory, which is allowable encroachment in residential dwelling units, and/or as an allowable associated shelf.

A countertop itself doesn't rely on the revolving cone model, but an articulated side support bracket such as shown in post #3 absolutely relies on the revolving cone model -- and none of the accessibility standards explicitly allow or endorse that model.

 

[Yikes]

I repeat, there is nothing in 604.3.3 that limits the dimensional extent of the of an allowable overlap into the toilet space. They could have a 12” thick solid floating “associated shelf” instead of a 2” thick shelf with 10” long side brackets, and that floating shelf would comply with 604.3.3.

Once you have determined that the vanity counter is either a part of an allowable lavatory or is an allowable associated shelf, it Is an allowable overlap. Period. No need to refer to rotating cones to justify it. A rotating cone clearance at the overlap may be “best practice”, but it is irrelevant to the code compliance of the shelf support.

 

[mark handler]

The real problem is side transfer

 

[Yikes]

The real problem is side transfer
View attachment 12172

And yet, for some reason the powers that be have determined it’s not a significant problem in residential dwelling units. Otherwise they would not have allowed the lav encroachment.

 

[redeyedfly]

The entire under-sink cabinetry has to be removable.

A117.1-2017:

It doesn't say the front of the vanity. It says "The cabinetry can be removed.." Leaving the side panel obviously doesn't leave the 60-inch maneuvering clearance required for the water closet unobstructed.

I've seen some crazy interpretations but this sets a new bar. Nowhere does it say the entire under sink cabinetry has to be removed. 1103.11.2.2 says the lav has to comply with 606 which requires a forward approach. Then it allows an exception to provide full cabinetry if it is removable to provide the forward approach from 606.

The exception is from the 606 requirements, not the WC clearance

The goal of a Type A is not to provide a 100% Accessible bathroom, it is to provide a space which is adequate for a person in a wheel chair with minimal effort.