Accessible shower - projection into clear space allowed?

[NCRooster]

Came across this diagram of an accessible shower the other day. I was under the assumption that nothing was allowed within the clear space in front of the shower (with the exception of sinks in the case of roll-in showers), but this shows the toilet grab bar overlapping the clearance. Am I missing something here? For reference, I'm using IBC 2021 and 2017 A117.1.

 

[walker.t]

Came across this diagram

What is the source of this diagram? This doesn’t affect your question, but the floor clearance at the lavatory should extend to the faucet levers.

I was under the assumption that nothing was allowed within the clear space in front of the shower (with the exception of sinks in the case of roll-in showers), but this shows the toilet grab bar overlapping the clearance. Am I missing something here? For reference, I'm using IBC 2021 and 2017 A117.1.

Unfortunately ADA/A117.1 305 does not state what the floor clearance is allowed to overlap. A clue that the intent of the ADA is that grab bars not overlap floor clearances may be inferred from several diagrams in the U.S. Access Board Technical Guide Chapter 6 regarding bathrooms:


This shows a door maneuvering clearance shifted away from the wall because there is a grab bar along the wall by the door. I know that’s a door, but maybe it helps clarify the general intent of the floor clearances.

Also in the same document we see a shower pulled away from the wall with a side grab bar at the toilet, maybe they did that so the grab bar wouldn’t overlap the clearance at the shower:





Another section of the same document says, “No elements, including lavatories, can overlap this clearance as they would impede transfer.”

The preceding images are found here:

U.S. Access Board - Chapter 6: Toilet Rooms

The U.S. Access Board is a federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards for the built environment, transportation, communication, medical diagnostic equipment, and...

www.access-board.gov

The U.S. Access Board technical documents are not law but maybe the comments above indicate that the intent was that grab bars not overlap floor clearances.

With all that said, it’s too bad that 305 doesn’t address the topic of overlapping elements. Compare that with ADA 604.3.2 and A117.1 604.3.3, these give us a list of things the clearance around the water closet is allowed to overlap, one of which is the grab bars around the toilet.

Regarding the overlap with a lavatory, remember that ADA 608.2.2.1 and A117.1 608.2.2.2 require that the lavatory overlapping the floor clearance at the shower not be located next to the seat or controls.

 

[mark handler]

Toilet Clearance In The Restroom

What can overlap the toilet clearance in the restroom?

abadiaccess.com

 

[walker.t]

Toilet Clearance In The Restroom

What can overlap the toilet clearance in the restroom?

abadiaccess.com

Thanks for sharing this article, looks like they have a lot of other interesting blog posts. Their photographs are helpful, reminds me of a thread started by jar546, I thought this thread generated a very decent discussion:

Lav Access

Acceptable or not?

www.thebuildingcodeforum.com

 

[NCRooster]

What is the source of this diagram? This doesn’t affect your question, but the floor clearance at the lavatory should extend to the faucet levers.

Great catch on the lavatory clearance - I'd missed that. It's just one of the first google results for "ada shower plan" - a coworker of mine was showing this plan to me while we were discussing the bathroom layouts on a project.

I agree that the intent is surely that grab bars and other elements can't overlap the shower clearance. It's a pity that this isn't clearly stated.

Toilet Clearance In The Restroom

What can overlap the toilet clearance in the restroom?

abadiaccess.com

Thanks for sharing this. I will definitely go through the other blog posts on there. Makes me think of this website:

ADA Accessibility Articles — reThink Access - Registered Accessibility Specialist | TDLR RAS

We post articles covering accessibility topics & research of the ADA Accessibility Standards.

www.rethinkaccess.com

 

[NCRooster]

Lav Access

Acceptable or not?

www.thebuildingcodeforum.com

This is a great thread as well - thank you for sharing!

 

[walker.t]

Great catch on the lavatory clearance - I'd missed that. It's just one of the first google results for "ada shower plan" - a coworker of mine was showing this plan to me while we were discussing the bathroom layouts on a project.

Thank you for the compliment. Regarding the diagram, I was just wondering, I noticed it said “Fig. 27” and was wondering what the book or resource was. I found the same drawing online, it’s from a hardware supplier’s site.

It's a pity that this isn't clearly stated.

I agree.

Makes me think of this website:

ADA Accessibility Articles — reThink Access - Registered Accessibility Specialist | TDLR RAS

We post articles covering accessibility topics & research of the ADA Accessibility Standards.

www.rethinkaccess.com

I stumbled upon this site last year maybe when I was researching customer service counters, I like his annotated photographs.

This is a great thread as well - thank you for sharing!

You’re welcome!

 

[mjw_accessibility]

What about shoe molding? If the walls enclosing the shower are 48" apart (in a Type B unit), is the baseboard and molding allowed to overlap that? Access Board has told me molding is not allowed to overlap a required door maneuverability clearance because it is part of an accessible route, but I do not know if the same applies to bathroom fixture clearances.

 

[walker.t]

What about shoe molding? If the walls enclosing the shower are 48" apart (in a Type B unit), is the baseboard and molding allowed to overlap that? Access Board has told me molding is not allowed to overlap a required door maneuverability clearance because it is part of an accessible route, but I do not know if the same applies to bathroom fixture clearances.

I would assume that baseboard and shoe molding are also prohibited in fixture floor clearances per this line of thinking:

1. Door maneuvering clearance is required at doors so that the door can be considered accessible.
2. Door maneuvering clearance is not allowed to have baseboard and shoe mold per your communication with the U.S. Access Board.
3. Floor clearances are required at toilet and bathing facilities so those fixtures can be considered accessible.
4. Therefore floor clearances at toilet and bathing fixtures are not allowed to have baseboard and shoe mold.

It is interesting to note that the U.S. Access Board technical guides for toilet rooms and bathrooms do not show baseboard in any of the illustrations.

Here’s an interesting comment on a similar thread:

Where is the common sense in that requirement? Baseboards will not interfere with the operation of a wheel chair. The radius of the rear wheel and the height of the foot rest on the front make it a mute point to measure from the baseboard. Just to operate a wheel chair along an accessible route you will be a couple of inches from the wall for your hands to power the wheels.

You might consider contacting the NC Office of State Fire Marshal to see how they have handled this, they have provided me with helpful responses to a few questions I have emailed them in the past.

 

[mjw_accessibility]

I would assume that baseboard and shoe molding are also prohibited in fixture floor clearances per this line of thinking:

1. Door maneuvering clearance is required at doors so that the door can be considered accessible.
2. Door maneuvering clearance is not allowed to have baseboard and shoe mold per your communication with the U.S. Access Board.
3. Floor clearances are required at toilet and bathing facilities so those fixtures can be considered accessible.
4. Therefore floor clearances at toilet and bathing fixtures are not allowed to have baseboard and shoe mold.

It is interesting to note that the U.S. Access Board technical guides for toilet rooms and bathrooms do not show baseboard in any of the illustrations.

Here’s an interesting comment on a similar thread:


You might consider contacting the NC Office of State Fire Marshal to see how they have handled this, they have provided me with helpful responses to a few questions I have emailed them in the past.

Thank you,

I have had several discussions with them on a variety of accessibility topics. I might not always get the answer I want, but at least it is clear.

 

[walker.t]

Thank you,

You’re welcome.

I might not always get the answer I want, but at least it is clear.

I know what you’re saying but I think the fact that you’re asking the State officials for clarification shows that the answer you want is the right answer.

 

[mjw_accessibility]

You’re welcome.


I know what you’re saying but I think the fact that you’re asking the State officials for clarification shows that the answer you want is the right answer.

I am still waiting on a response from NC DOI directly, but a client of mine informed me that NC DOI called yesterday and allows the shower clearance to overlap baseboards and molding

 

[walker.t]

I am still waiting on a response from NC DOI directly, but a client of mine informed me that NC DOI called yesterday and allows the shower clearance to overlap baseboards and molding

Thank you, that’s good to know, I appreciate the follow-up.

 

[walker.t]

I am still waiting on a response from NC DOI directly

When you talk to NC DOI you might want to ask what the maximum projection is they allow for the baseboard and molding. Today I was looking at IBC 1005.7.2 (regarding encroachments into the required means of egress width,) it allows 1.5” for “nonstructural projections such as trim and similar decorative features.” So maybe they have determined a maximum encroachment into the clear floor space for the fixtures.

 

[brokenkeys]

The Bobrick Planning Guide has a similar image, but with different numbers. Perhaps that's from an old guide.

 

[walker.t]

The Bobrick Planning Guide has a similar image, but with different numbers. Perhaps that's from an old guide.

Your diagram shows the larger turning space required in A117.1, that may be why the other dimensions were increased.