Accessible toilet room

[Sifu]

In the attached drawing I see a few problems, but after reading multiple posts, codes and commentaries I can't put my finger on exact language for everything so I want to be sure. The adopted standard is the 2009 ANI 117.1.

Issues:
1- C1 is a 6 1/2" deep hand dryer, no mention of being recessed. I have found varying language and opinions for what is permitted in this space, but I am relatively certain a 6 -1/2" projection isn't permitted anywhere, much less within the maneuvering clearance.
2- The dryer is within the 18" maneuvering clearance for the door.

Things I think are OK:
The door swing overlaps the clear floor space for the dryer and the sink, but there is a 30x48 clear space beyond the arc of the door so I think this is allowed.
C4 is a baby station, and if 4" when folded I think would be would be allowed.
C2 is a 4 3/4" soap dispenser, but not on a circulation path so I think it is allowed.
The dryer encroaches on the clear floor space for the lavatory. I can't find language allowing this but it seems this wouldn't be an issue in a single user situation.
Additional thoughts and arguments are appreciated concerning code violations (not bad ideas)

 

[Mr. Inspector]

The dryer could not be a protruding more than 4" from the wall.

 

[RLGA]

I see your point and agree with your confusion.

Protruding object limitations pertain only to circulation paths, a defined term. The area within a single-user restroom would not be considered a circulation path; thus, the 4-inch protrusion limitation would not apply.

The requirements for clear floor spaces do not address protruding objects above the floor surface. By its name, the clear floor space appears to address only the floor surface, not an extruded volume that extends upward from the floor surface to a maximum height. On the other hand, the requirements address toe and knee clearances, which lends some credence to the idea that it is a three-dimensional volume. However, they fail to mention other objects that may protrude into that volume. Logic would dictate that no other objects are permitted within that space. A simple edit could clear this up:

"305.4 Knee and Toe ClearanceProtruding Objects. No object shall protrude into the clear floor space within a height of 80 inches (2030 mm). Unless otherwise specified, the clear floor space shall be permitted to include knee and toe clearance complying with Section 306."​

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Similarly, the maneuvering clearances at doors prohibit knee and toe clearances but not other objects. A simple edit can correct that situation, too:

"404.2.3 Maneuvering Clearances. Minimum maneuvering clearances at doors shall comply with Section 404.2.3 and shall include the full clear opening width and height of the doorway. Required door maneuvering clearances shall not include knee and toe clearances. No object shall protrude into the maneuvering clearance except for approved door hardware."​

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I know these changes do not help you now, but maybe somebody on the committee will see them and look to include them in the next edition.

In the meantime, since there is no explicit prohibition on the indicated location, you can ask them if they are willing to accept the elevated risk of injury to users who could very likely hit the unit.

 

[Sifu]

Thanks RLGA, for the detailed info and the validation for my confusion. I am providing a comment that the hand dryer can't be in the clear floor space. If I take this as the one-dimensional floor surface it makes no sense, otherwise they could place an object 1" off the floor and it would be acceptable. I don't think anyone could make that argument successfully. The real quandary is going to be in their response. If they recess it to create only a 4" protrusion is that acceptable? Or 2"? So by degree I will try to determine within that grey area what does not comply with the intent. I am thinking the 4" protrusion limit seems reasonable since it is applied elsewhere. It very well may be that they intend on recessing it, but the fixture schedule calls it 6 1/2" and since they do not indicate it will be recessed I will take their info at face value. Your suggested revisions make great sense, I wish we had that clarity, if not in the code then at least in some commentary, but I could find nothing definitive in either the ANSI standards or the ADA guidance. Maybe I'll try to get a staff opinion or interp from ANSI.

 

[Mr. Inspector]

Defintion:
Circulation Path: an exterior or interior way of passage provided for pedestrian travel, including but not limited to walks, hallways, courtyards, elevators, platform lifts, ramps, stairways and landings.

I would think this would mean protruding objects in circulation paths in toilet rooms or any other space are not allowed too. I enforce this all the time and never had any problems.
But I always thought it was odd that A117.1 did not have any height requirements for accessible routes, door maneuvering spaces, turning spaces and clear floor spaces. You would have to go all the way to the egress chapter to find this but many of the mentioned spaces may not be on a egress route.

 

[Sifu]

I had a good conversation with ICC/ANSI about this. First, they acknowledged that this has been somewhat of an on-going issue and they are working on it for the next edition. Since the code is somewhat grey, the best that can be given is an opinion, based on my specific circumstance. So here is my opinion, based in part on other opinions in the absence of black and white language:

Does the dryer hinder the use of the maneuvering clearance to use the door? At a mounting height above the door hardware, probably not as a wheel chair or walker would still be able to use that space to offset and operate the door. However, if for example, the 6 1/2" projection went to the floor as in some paper towel dispensers, then it would hinder the use of the space. Or, if the projection was of such a depth as to make it uncomfortable for the use even if the wheelchair or walker would fit under it...putting the user nose to nose with the projection, that would also hinder the use of the maneuvering space.

We spoke of the practice of some to call ANY projection a violation, largely to avoid potential litigation, as maybe not being with the intent of the code. For now, I guess we have to rely on our own arbitrary definition of what will meet the intent of the code or not. For me, if the projection has space under it that would allow the user to utilize the space for it's intended purpose, and (this is stickier) the projection is shallow enough so as to not negatively impact the use of the space, then it can be there.

Which brings me back to protruding objects on a circulation path. The definition of circulation path does not include bathrooms, but the definition is not limited to just what is listed. If the intent is that someone is walking down a corridor with their cane and the protruding object is not detected then they smack their face, then that wouldn't apply in this small single use toilet room. But if the intent is that a toilet room is on a circulation path, what about the sink? I don't see the sink as a protruding object on a circulation path, but some others do. "Not limited to" presents another arbitrary decision (2017 commentary: "Which part of a floor is not a circulation path is subjective"). In this case, if I say the dryer can't project more than 4" because all floors in a bathroom are a circulation path, I would then have to say cane detection is needed at the sink because the bottom edge of the sink is at 29". I'm perfectly comfortable saying the dryer presents a potential hazard to someone who walks in the door and makes an immediate right hand turn into the side of the dryer. I am far less comfortable saying the sink presents an object on the circulation path.

So, since the decision is subjective, I am thinking about saying the route into the room and past the dryer is a circulation path and should not include projections greater than 4", but that there is not a circulation path in front of the sink.

So let me have it, good, bad or indifferent.

 

[RLGA]

Defintion:
Circulation Path: an exterior or interior way of passage provided for pedestrian travel, including but not limited to walks, hallways, courtyards, elevators, platform lifts, ramps, stairways and landings.

I would think this would mean protruding objects in circulation paths in toilet rooms or any other space are not allowed too. I enforce this all the time and never had any problems.
But I always thought it was odd that A117.1 did not have any height requirements for accessible routes, door maneuvering spaces, turning spaces and clear floor spaces. You would have to go all the way to the egress chapter to find this but many of the mentioned spaces may not be on a egress route.

You're looking at the definition in the 2017 edition of ANSI A117.1, which I don't think applies in this situation.

The definition in the 2009 ANSI A117.1 (and IBC) is "[a]n exterior or interior way of passage from one place to another for pedestrians."

In either case, the floor area provided within a room for maneuvering is not a passage (i.e., circulation path) unless it leads to another space, room, or function. In a multi-user restroom, there is a circulation path from the door to the toilet compartments, to the lavatories, and back to the door. However, in a single-user restroom, the floor area is used for maneuvering and not passage. It is a similar situation within walk-in closets. Most closets have a clothes rod and shelf located more than 27 inches and less than 80 inches above the floor and extending more than 4 inches into the floor area, yet no one requires the shelf and rod to be removed or reduced to a 4-inch depth. That is because the floor area within the closet is not a circulation path but a maneuvering area.

Regardless of what the definitions say and how they are interpreted, I agree with you that in some situations (like clear floor spaces, door maneuvering clearances, and turning spaces), protruding objects should be limited. However, there is an absence of definitive direction that leads to inconsistent interpretation.

 

[Sifu]

You're looking at the definition in the 2017 edition of ANSI A117.1, which I don't think applies in this situation.

The definition in the 2009 ANSI A117.1 (and IBC) is "[a]n exterior or interior way of passage from one place to another for pedestrians."

In either case, the floor area provided within a room for maneuvering is not a passage (i.e., circulation path) unless it leads to another space, room, or function. In a multi-user restroom, there is a circulation path from the door to the toilet compartments, to the lavatories, and back to the door. However, in a single-user restroom, the floor area is used for maneuvering and not passage. It is a similar situation within walk-in closets. Most closets have a clothes rod and shelf located more than 27 inches and less than 80 inches above the floor and extending more than 4 inches into the floor area, yet no one requires the shelf and rod to be removed or reduced to a 4-inch depth. That is because the floor area within the closet is not a circulation path but a maneuvering area.

Regardless of what the definitions say and how they are interpreted, I agree with you that in some situations (like clear floor spaces, door maneuvering clearances, and turning spaces), protruding objects should be limited. However, there is an absence of definitive direction that leads to inconsistent interpretation.

I am up in the air on the circulation path issue in a single user restroom, I have read several opinions in the google-verse and on this forum and find I am not alone in my uncertainty, but the real reason I am headed in that direction is the feeling that the dryer located where it is presents a hazard as a protruding object, due to its location between the door and the sink. It is a feeling based on the perceived notion that a user will typically enter at an angle towards the direction that the door opens and may be met head-on with the protruding dryer. Maybe it wouldn't feel that way if I could experience it first hand but based on the drawing it concerns me.

And you are correct, I was using the definition from the '17, but only because it seems to refine the '09. Both include the "way of passage" language, which could be applicable to literally anything. Unless definitive direction can be given, we each have to make our "subjective" decision, and in this case I think there is a hazard that really doesn't need to be there. So while I don't think presents a usability issue for the maneuvering space, I do think it presents a potential hazard from someone walking into it and maybe we agree this might be a location where the protruding object needs to be limited even if it is not a defined circulation path. If it were on the other wall where the baby table is I might not see the same potential and come up with a different conclusion.

I appreciate the discussion immensely.

 

[Jean Tessmer-HI]

In the attached drawing I see a few problems, but after reading multiple posts, codes and commentaries I can't put my finger on exact language for everything so I want to be sure. The adopted standard is the 2009 ANI 117.1.

Issues:
1- C1 is a 6 1/2" deep hand dryer, no mention of being recessed. I have found varying language and opinions for what is permitted in this space, but I am relatively certain a 6 -1/2" projection isn't permitted anywhere, much less within the maneuvering clearance.
2- The dryer is within the 18" maneuvering clearance for the door.

Things I think are OK:
The door swing overlaps the clear floor space for the dryer and the sink, but there is a 30x48 clear space beyond the arc of the door so I think this is allowed.
C4 is a baby station, and if 4" when folded I think would be would be allowed.
C2 is a 4 3/4" soap dispenser, but not on a circulation path so I think it is allowed.
The dryer encroaches on the clear floor space for the lavatory. I can't find language allowing this but it seems this wouldn't be an issue in a single user situation.
Additional thoughts and arguments are appreciated concerning code violations (not bad ideas)
View attachment 9880

Sifu, the only thing I see missing it the 18" space on the pull side of the door that is placed in a 60 inch deep by 54 inch wide (offset on the 18 inch space to the latch side of the door) clear floor space the pull side door face. Other wise I think it is ok. I would recommend you use life size toilet cad drawing as it apprears your toilet is too shallow. There are free cad drawing you should use from Amercian Standard Cadet Right Height or Kohler. Those elongated toilets are usually 28 to 30 inches to the end of the bowl protruding into the room.

 

[Sifu]

Sifu, the only thing I see missing it the 18" space on the pull side of the door that is placed in a 60 inch deep by 54 inch wide (offset on the 18 inch space to the latch side of the door) clear floor space the pull side door face. Other wise I think it is ok. I would recommend you use life size toilet cad drawing as it apprears your toilet is too shallow. There are free cad drawing you should use from Amercian Standard Cadet Right Height or Kohler. Those elongated toilets are usually 28 to 30 inches to the end of the bowl protruding into the room.

Appreciate the input. I am not the designer, just the lowly plan reviewer, so I can't control the data. I have often wondered about the boiler plate fixtures used in the drawings, but I have to go with what they show me.

 

[JPohling]

The 2017 ANSI definition says "provided for pedestrian travel"
The 2009 ANSI definition says "from one place to another"

I do not think the maneuvering space in a single occupancy toilet room would be a circulation path. I do tag situations like this where it encroaches more than 4" into the wheelchair space at the lav. This may allow a projection more than 4" from the wall for the device depending upon the CL dim to the sink from the side wall. I have seem towel dispensers that project 10" and more. Where would you draw the line?

That also applies to the 18" strike side clearance, but I allow a projection up to 8" in this area as if the door was recessed.

 

[Sifu]

The 2017 ANSI definition says "provided for pedestrian travel"
The 2009 ANSI definition says "from one place to another"

I do not think the maneuvering space in a single occupancy toilet room would be a circulation path. I do tag situations like this where it encroaches more than 4" into the wheelchair space at the lav. This may allow a projection more than 4" from the wall for the device depending upon the CL dim to the sink from the side wall. I have seem towel dispensers that project 10" and more. Where would you draw the line?

That also applies to the 18" strike side clearance, but I allow a projection up to 8" in this area as if the door was recessed.

The recessed door approach is one I discussed with ICC for the maneuvering clearance. As to where to draw the line... that is the question. I would also say that "provided for pedestrian travel" and "from one place to another" can be applied anywhere. Do they intend it to apply everywhere? I don't think so but without better guidance we are left to make that determination. Like I said, if it were not in the direct line of travel as you enter the door towards the sink I might not be as critical. I'll let this stew for a few days and maybe I'll see it differently. If not, I'm sure the architect will throw some shade my way, I'll keep an open mind.

 

[Mr. Inspector]

If they are traveling from the door to the lavatory it's because it was "provided for pedestrian travel"
If they are traveling from the door to the lavatory they are moving "from one place to another"
Nothing about traveling to rooms or spaces in the definition.