Ambulatory stall door clearance?

[TurboArch]

ADA says that an ambulatory stall must be 60" deep minimum. In 604.8.2.2, it states that Toilet compartment doors shall comply with 404, except that for a latch side approach the door clearance can be reduced to 42". I have a plan reviewer telling me that in addition to the 42" on the outside of the stall, I also need to provide the 48" maneuvering clearance on the inside of the stall per 404.2.4.1, and that the toilet cannot encroach.

In my entire 25 year career, I don't think I have ever seen this requirement enforced or even questioned. I have seen dozens of ambulatory stalls that were designed with the 60" minimum depth per the diagram in the code without issue. If this is in fact a requirement, then why did ADA even provide a minimum 60" stall depth? That would be impossible to achieve as it would only leave you with 12" for a toilet (60"-48"=12"). A 12" deep toilet does not exist.

I feel like the 48" maneuvering clearance is intended for people in wheelchairs, but an ambulatory stall is not for people in wheelchairs. It seems like common sense, but I can't find support for that in the code.

What am I missing here?

 

[walker.t]

I have a plan reviewer telling me that in addition to the 42" on the outside of the stall, I also need to provide the 48" maneuvering clearance on the inside of the stall per 404.2.4.1, and that the toilet cannot encroach.

Seems odd to me that a plans examiner is checking for conformance with ADA, I heard somewhere that generally they don’t do that because that’s Federal law.

I noticed some time ago that neither ADA nor A117.1-2009 included an exception for door maneuvering clearances on the inside of the toilet compartments - that’s a gross oversight in my opinion. But at least the omission was corrected in A117.1-2017:

A117.1-2017 604.10 Ambulatory Accessible Toilet Compartments > 604.10.3 Doors (partial quote)
Ambulatory accessible toilet compartment doors, including door hardware, shall comply with Section 404.
Exceptions:
2. Within the ambulatory accessible toilet compartment, maneuvering clearances at the doors shall not be required to comply with Section 404.

It seems like common sense, but I can't find support for that in the code.

You might try showing the plans examiner how A117.1-2017 has the exception, maybe that will help them understand the intent of the ADA. I appreciate your plans examiner’s desire to stick to the letter of the code, but this is a case where a little common sense should be applied.

 

[Yankee Chronicler]

Both A117.1 and the ADAS provide text and diagrams that establish the required dimensions for accessible toilet stalls. If the plan reviewer wants anything other than that, he should take it up with the Access Board and with the ICC.

 

[jar546]

What part of this does he not understand? Send him a link to this educational thread.

604.10.2 ​

The minimum area of an ambulatory accessible toilet compartment shall be 60 inches (1525 mm) minimum in depth and a width of 35 inches (890 mm) minimum and 37 inches (940 mm) maximum.

604.10.3 ​

Ambulatory accessible toilet compartment doors, including door hardware, shall comply with Section 404. The door shall be self-closing. A door pull complying with Section 404.2.6 shall be placed on both sides of the door near the latch. Compartment doors shall not swing into the required minimum area of the compartment.

Exceptions:

1. Outside of the ambulatory accessible toilet compartment, where the approach is to the latch side of the compartment door, clearance between the door side of the compartment and any obstruction shall be 42 inches (1065 mm) minimum.
2. Within the ambulatory accessible toilet compartment, maneuvering clearances at the door shall not be required to comply with Section 404.

INSIGHTS (1)

604.10.4 ​

Grab bars shall comply with Section 609. Side wall grab bars complying with Section 604.5.1 shall be provided on both sides of the compartment.

 

[TurboArch]

Thanks all for the great info. I have to clarify something. My project is in Texas, which has adopted it's own version of ADA (called the Texas Accessibility Standards). The rules are almost identical to ADAAG, even with the same section numbers. So I was trying to keep my post generic in the hopes of getting input from a wider audience that might not have responded if I had just mentioned the TAS code.

Even though the TAS handbook has not been updated in this section to match A117.1-2017, I think this gives me solid ground to argue my stance. That and the fact that I can point to examples all over the state where ambulatory stalls have been built 60" deep over the past 20 years without rampant lawsuits.

 

[Yankee Chronicler]

The 2010 ADAS has the same illustration of the ambulatory compartment, as figure 604.8.2.

The 1994 ADAAG didn't have any provision for an ambulatory accessible toilet stall. However, it did have an "alternate" stall, which was 36" wide but either 66" or 69" deep, depending on whether the water closet was floor mounted or wall hung. Section 4.17, Figure 30.

 

[TurboArch]

The 2010 ADAS has the same illustration of the ambulatory compartment, as figure 604.8.2.

The Texas Accessibility Standard has the exact same illustration. But according to the reviewer, the 60" is a minimum and does not excuse you from meeting the other clearance requirements. My response was, "why would they provide a minimum clearance that is physically impossible to achieve". It makes no sense.

 

[Hien NGUYEN]

You said you have 25 years experience ?
Then you would know how to deal with perhaps young and ambitious plan checkers. Sometimes they just making a mistake and you need to communicate with them, either nicer, clearer or making a strong point of requesting a change of reviewer. I did that.

 

[steveray]

Seems odd to me that a plans examiner is checking for conformance with ADA, I heard somewhere that generally they don’t do that because that’s Federal law.

I noticed some time ago that neither ADA nor A117.1-2009 included an exception for door maneuvering clearances on the inside of the toilet compartments - that’s a gross oversight in my opinion. But at least the omission was corrected in A117.1-2017:



You might try showing the plans examiner how A117.1-2017 has the exception, maybe that will help them understand the intent of the ADA. I appreciate your plans examiner’s desire to stick to the letter of the code, but this is a case where a little common sense should be applied.

Now they just need to fix the depth to align with the rest of the stalls....

 

[arwat23]

My response was, "why would they provide a minimum clearance that is physically impossible to achieve". It makes no sense.

In my state, we have a few instances of minimum accessibility requirements conflicting with other accessibility requirements. One section saying there's a minimum depth doesn't necessarily mean another section can't force the depth to be bigger.

As far as I see, there's nothing the 2010 ADAS or 2012 TAS that explicitly forbids the maneuvering clearance required by 404 from being required within the compartment. Although it seems damn near impossible to meet the be close to the minimum code-required depth with almost any toilet.

I can see where the plans examiner is coming from, code isn't being clear. That said, if A117.1 / the rest of the county can do it, I think the intent of ADAS is that a maneuvering clearance isn't required in the ambulatory stall.