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Adding a non-accessible toilet room

Sifu

Sifu

SAWHORSE
Joined
Sep 3, 2011
Messages
2,811
'21 IBC/IEBC/IPC. School is adding a single user toilet room which is not accessible. It is directly beside an accessible single user toilet room. No other toilet rooms are in the area. IEBC 306.3.1 tells me the number of toilet rooms that are accessible is not required to exceed that of the IBC. IBC says if clustered 50% must be accessible. Since there are two clustered, the new one does not require access if both are for use by either gender...correct? If it is not required to be accessible, is the door maneuvering space inside the toilet room still required?
 
'21' IBC Section 2903.1.1 and 2903.1.4 may be what your looking for?

I would thing the clearance in front of the toilet would need to be checked and the width needing to meet the side to side measurement. All other requirement like wall finishes need to be checked.
 
The plumbing clearances are met, it is the accessibility requirement for the door maneuvering space I am questioning.
 
Inside the room? No. It's not accessible, so there should be no need for the maneuvering clearance inside the toilet room.
 
2010 ADASAD 202.3 Alterations, where compliance with applicable requirements is technically infeasible, the alteration shall comply with the requirements to the maximum extent feasible.
 
mark handler said:
2010 ADASAD 202.3 Alterations, where compliance with applicable requirements is technically infeasible, the alteration shall comply with the requirements to the maximum extent feasible.
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Mark, I think post #1 is seeking concurrence that it already will comply with the code requirement for min. 50% accessible clustered single accommodation toilets. Therefore there is no need to invoke technical infeasibility.
 
Yikes said:
Mark, I think post #1 is seeking concurrence that it already will comply with the code requirement for min. 50% accessible clustered single accommodation toilets. Therefore there is no need to invoke technical infeasibility.
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ALL new restrooms SHALL comply.....to the extent feasible
 
mark handler said:
ALL new restrooms SHALL comply.....to the extent feasible
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2010 ADAS § 202.3: Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Chapter 2.

This, to my eyes, indicates that Ch 2 determines what's required, and Ch 2 (213.2, exception 4) states that only 50% of clustered single-user toilet rooms need to be accessible. As long as that 50% is being hit, then it meets code requirements.

If all new restrooms need to be fully accessible, what's the point of 213.2 exception 4?
 
There are conflicts in the different codes.
Can you do it under the IBC Ch. 11, yes, cluster exemption.
Can you do it under ADA, Yes, if you show and invoke technical infeasibility.
 
mark handler said:
There are conflicts in the different codes.
Can you do it under the IBC Ch. 11, yes, cluster exemption.
Can you do it under ADA, Yes, if you show and invoke technical infeasibility.
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Both ADAS and IBC (1110.2, exception 2) have the same language for the cluster exception. There is no contradiction that I see and no need to invoke technical infeasibility (assume that it's actually technically infeasible, which it sounds like it isn't given the original post).

If I'm missing something, please point me to that. I'm genuinely asking :) Not trying to be combative. If I'm missing something, I'd like to know.
 
Would not be technically infeasible. I think the cluster provision stands.
 
arwat23 said:
If I'm missing something, please point me to that. I'm genuinely asking :) Not trying to be combative. If I'm missing something, I'd like to know.
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I'm a bit confused and now think I've been doing this all wrong?

I'll try to make through the week.
 
arwat23 said:
Both ADAS and IBC (1110.2, exception 2) have the same language for the cluster exception. There is no contradiction that I see and no need to invoke technical infeasibility (assume that it's actually technically infeasible, which it sounds like it isn't given the original post).

If I'm missing something, please point me to that. I'm genuinely asking :) Not trying to be combative. If I'm missing something, I'd like to know.
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There are sections under the 2010ADASAD that require ALL new RR facilities to be accessible.
Existing facilities shall be made to the extent feasible.
 
mark handler said:
There are sections under the 2010ADASAD that require ALL new RR facilities to be accessible.
Existing facilities shall be made to the extent feasible.
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Which section specifically states that? Again, genuine question, as I cannot seem to find that.
 
We often use the clustered 50% unisex approach in new construction. These "RR facilities" are compliant in terms of accessibility.
 
ADASAD 213.2 says: "Where toilet rooms are provided, each toilet room shall comply with 603". However, Exception 4 says: "Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603."
 
mark handler said:
chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://archive.ada.gov/regs2010/2010ADAStandards/2010ADAStandards.pdf
Compliance Date for Title II If the start date for construction is on or after March 15, 2012, all newly constructed or altered State and local government facilities must comply with the 2010 Standards.
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Yes, the building or facility as a whole must comply with ADAS.

ADAS, however, specifically exempts 50% of clustered single-user restrooms from being accessible. If what you reference says that the altered facilities need to comply with ADAS (which i show I read it), then the 50% exception still applies since that's in ADAS.

If that language you reference applies to individual rooms, then the ADAS 50% exception hold no power with Title II entities (or Title III I believe... I think that has similar language to what you reference). If this reads like "all new rooms shall be accessible", then that exception means literally nothing (as does many other exceptions within ADAS).

The way I read this, this isn't saying that every single new or altered room needs to be accessible. It just means that the facility the room is in needs to comply with ADAS as applicable. Since there's that exception within ADAS, the new restroom doesn't need to be accessible.
 
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arwat23 said:
Yes, the building or facility as a whole must comply with ADAS.

ADAS, however, specifically exempts 50% of clustered single-user restrooms from being accessible. If what you reference says that the altered facilities need to comply with ADAS (which i show I read it), then the 50% exception still applies since that's in ADAS.

If that language you reference applies to individual rooms, then the ADAS 50% exception hold no power with Title II entities (or Title III I believe... I think that has similar language to what you reference). If this reads like "all new rooms shall be accessible", then that exception means literally nothing (as does many other exceptions within ADAS).

The way I read this, this isn't saying that every single new or altered room needs to be accessible. It just means that the facility the room is in needs to comply with ADAS as applicable. Since there's that exception within ADAS, the new restroom doesn't need to be accessible.
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It it is NEW, IMPO, It will need to be accessible. If it is existing, IMPO, It can be Partially Accessible.
 
Mark, 2213.2 exc. #4 is the full extent of scoping for a brand new building to be fully compliant with ADA/CBC 11B, as it applies to clustered single-user restrooms.
There is nothing in the code that compels more than a minimum of 50% of single-user restrooms clustered in a single location to be accessible.

A similar analogy is when a 50 car parking lot has 2 accessible parking stalls. That means 48 stalls are nonaccessible. But we don't say the lot is "nonaccessible", and we don't say the lot is "partially accessible". we can rightfully call it a "fully accessible parking lot", because it met the minimums of table 208.2.
 
Yikes said:
Mark, 2213.2 exc. #4 is the full extent of scoping for a brand new building to be fully compliant with ADA/CBC 11B, as it applies to clustered single-user restrooms.
There is nothing in the code that compels more than a minimum of 50% of single-user restrooms clustered in a single location to be accessible.

A similar analogy is when a 50 car parking lot has 2 accessible parking stalls. That means 48 stalls are nonaccessible. But we don't say the lot is "nonaccessible", and we don't say the lot is "partially accessible". we can rightfully call it a "fully accessible parking lot", because it met the minimums of table 208.2.
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absolutely correct. Like I posted previously...............We often use the clustered 50% unisex approach in new construction. These "RR facilities" are compliant in terms of accessibility.
 
Yikes said:
A similar analogy is when a 50 car parking lot has 2 accessible parking stalls. That means 48 stalls are nonaccessible. But we don't say the lot is "nonaccessible", and we don't say the lot is "partially accessible". we can rightfully call it a "fully accessible parking lot", because it met the minimums of table 208.2.
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Not a good analogy, like apples and oranges. “false equivalence”
There is nothing in the "parking" sections of any code or standard, that requires all new spaces be accessible.
NOT TRUE for the codes and standards that require ALL NEW, be accessible.
 
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mark handler said:
Not a good analogy, like apples and oranges. “false equivalence”
There is nothing in the "parking" sections of any code or standard, that requires all new spaces be accessible.
NOT TRUE for the codes and standards that require ALL NEW, be accessible.
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If that’s the case, then under that logic, why isn’t every new toilet compartment in a multi-user accessible restroom also required to be accessible?

Let’s see where this idea is coming from that ALL NEW must be accessible.

mark handler said:
Compliance Date for Title II If the start date for construction is on or after March 15, 2012, all newly constructed or altered State and local government facilities must comply with the 2010 Standards.
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It doesn’t say ALL NEW must be accessible.
It says that all new must comply with the 2010 Standards. That’s a huge difference.

The 2010 Standards for new facilities only require 50% of clustered single user restrooms to be accessible. Compliance achieved.
 
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