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Are Urinals Required in Unisex Restrooms?

arwat23

SAWHORSE
Joined
Sep 19, 2023
Messages
442
Location
California
Not sure if this belongs in the plumbing code forum, but is there a specific section of code that would allow me to remove a urinal from a single user unisex toilet room?

My firm and I are butting heads on this. It makes sense, logically, to not include a urinal in a single user unisex toilet room, but I can't find a section of code (California or otherwise) that says we can omit a urinal if it's required by CPC Table 422.1 or IBC Table 2902.1.

I'm working on a project with multiple single user toilet rooms, but the above mentioned tables say we need at least one urinal in one of the restrooms. There are no other urinals (or group restrooms) in the building either. Is there a section of code that speaks to this?
 
CPC Table 422.1 establishes the minimum number of fixtures required for specific occupancies, assuming 50% male and 50% female. This includes the minimum number of urinals for males. CPC 422.1 further clarifies:
  • "Where information submitted indicates a difference in the distribution of the sexes such information shall be used to determine the number of fixtures for each sex."
Thus, the only way to eliminate all urinals is for the AHJ to agree that there will be 0% males at the building (example: a convent).


Once you have established the minimum number of fixtures, you can arrange them in multiple ways in California:
  1. Multi-user male facilities (with urinals), and multi-user female facilities.
  2. Multiple single-accommodation facilities (SAF), of which there would need to be urinals (along with toilets) in each SAF up to the # of urinals established elsewhere in table 422.
  3. Multi-user all-gender facilities. In this one, DSA is proposing creation of a privacy compartment for urinals (just like toilet compartments, but with urinals instead of toilets in them): https://www.dgs.ca.gov/-/media/Divisions/DSA/Publications/access/DraftCodeChangeProposal_221104.pdf
  4. some combination of 1, 2, and 3 above to add up to the number of fixtures required by Table 422.1.
 
Is California that different from the model ICC codes? In the IBC and IPC (ICC versions) urinals are NEVER required. Urinals are allowed as a substitution for up to 50% of the required water closets in male toilet rooms.
 
Minimum plumbing fixtures are also spelled out in IBC 2902 and Table 2902.1. Does California delete that?

The IBC section and table do not "require" urinals. As I mentioned above, the IBC (and the IPC) allows urinals to be substituted for up to 50% of the required number of water closets.
 
Minimum plumbing fixtures are also spelled out in IBC 2902 and Table 2902.1. Does California delete that?

The IBC section and table do not "require" urinals. As I mentioned above, the IBC (and the IPC) allows urinals to be substituted for up to 50% of the required number of water closets.
Yes, California did not adopt IBC chapter 29. Instead, our state adopted the Uniform Plumbing Code, which has a mandatory minimum number of urinals based on the number of male occupants.
Beyond that minimum number of urinals, you can also additionally provide even more urinals as a 1:1 substitution for water closets, up to 50%, when calculating the number of WCs required for males.
 
Our state amendment to the UPC that requires a urinal be installed in addition to the minimum WC requirements.

g. Single-user unisex facilities shall include a urinal in food service establishments or any establishment that sells alcoholic beverages for on-site consumption.
 
CPC Table 422.1 establishes the minimum number of fixtures required for specific occupancies, assuming 50% male and 50% female. This includes the minimum number of urinals for males. CPC 422.1 further clarifies:
  • "Where information submitted indicates a difference in the distribution of the sexes such information shall be used to determine the number of fixtures for each sex."
Thus, the only way to eliminate all urinals is for the AHJ to agree that there will be 0% males at the building (example: a convent).


Once you have established the minimum number of fixtures, you can arrange them in multiple ways in California:
  1. Multi-user male facilities (with urinals), and multi-user female facilities.
  2. Multiple single-accommodation facilities (SAF), of which there would need to be urinals (along with toilets) in each SAF up to the # of urinals established elsewhere in table 422.
  3. Multi-user all-gender facilities. In this one, DSA is proposing creation of a privacy compartment for urinals (just like toilet compartments, but with urinals instead of toilets in them): https://www.dgs.ca.gov/-/media/Divisions/DSA/Publications/access/DraftCodeChangeProposal_221104.pdf
  4. some combination of 1, 2, and 3 above to add up to the number of fixtures required by Table 422.1.
We've used the new 2024 UPC exception that states that unisex restrooms can replace separate gendered restrooms as long a the fixture count is kept to not require separate facilities. Even before then, most jurisdictions didn't care if all toilets were in unisex single-user restrooms as long as we met the fixture count.

I agree with you that we can't get rid of the urinals based on those sections. Big shame for our client, but not much we can do about that.
 
Minimum plumbing fixtures are also spelled out in IBC 2902 and Table 2902.1. Does California delete that?

The IBC section and table do not "require" urinals. As I mentioned above, the IBC (and the IPC) allows urinals to be substituted for up to 50% of the required number of water closets.
California uses UPC as a base instead of IPC. IBC Ch 29 is straight up removed from the California Building Code and instead we use UPC/CPC Table 422.1 for plumbing fixture count.

I don't believe UPC or CPC has that exception (replacing water closets with urinals up to a certain point) that IBC/IPC has unfortunately. If it does, I have yet to find it.
 
I don't believe UPC or CPC has that exception (replacing water closets with urinals up to a certain point) that IBC/IPC has unfortunately. If it does, I have yet to find it.
IMHO, I believe it is the intent.

2018 UPC

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footnote's 3 & 4 to the fixture table

Your client may not want the urinals. However, if they ask their female customers/employees I would bet they would have a strong opinion about that decision.
 
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There are three basic ways to build a gender inclusive restroom:

  • The men’s room model, with conventional urinals and toilet stalls
  • The women’s room model, with conventional toilet stalls only
  • The family restroom model, with multiple gender inclusive toilet rooms and common space for handwashing
In all three of these, privacy should be your paramount concern. When men, women, transgender, and intersex people all use the same facility, each individual must feel comfortable.

The first two options are ordinary restrooms designated for gender-neutral use. Urinals in a restroom meant for use by women might seem like a strange idea, but they conveniently reduce waiting times for female users. For utmost privacy we recommend modesty screens between each urinal, and floor-to-ceiling walls and doors for all stalls.

The third option affords all users the greatest privacy, but multiple toilet rooms with locking doors can make the project more expensive.
 
footnote's 3 & 4 to the fixture table

Your client may not want the urinals. However, if they ask their female customers/employees I would bet they would have a strong opinion about that decision.
They have and there is a VERY strong opinion. However, if it's required, then there isn't much we can do. The problem is our client only wants unisex restrooms due to what they do (urology), not separate gendered facilities, which typically works at their other locations since other buildings often have a central shared restroom that we can point to for the urinal requirement. Their practice more or less demands restrooms spread out around their suite (at least they way they want their space set up...). To keep it short, unisex restroom is the best for them from a functionality standpoint.

I guess on that note, how would you handle CPC/UPC 422.2 exceptions 2 and 3? If a space were to meet one of these exceptions, would a urinal still be required?
 
Now I understand why, and it makes sense in a urology office.
Restrooms accessible from the lobby/waiting area should meet code requirements.
Rooms used by patients for providing samples are not restrooms and therefore urinals should not be required.
 
Now I understand why, and it makes sense in a urology office.
Restrooms accessible from the lobby/waiting area should meet code requirements.
Rooms used by patients for providing samples are not restrooms and therefore urinals should not be required.
Three questions about this:

1. Even though the water closets and lavs in those "urology restrooms" are required by code to meet the plumbing fixture count, those would not be considered toilet rooms by code if they can be (but are not exclusively) used for providing samples? Or, for this to work, do those restrooms only be used for providing samples for this to work?

2. If those rooms are not considered toilet facilities, can we still stick a urinal in one to meet the fixture count? Asking because if they are not a "toilet facility", then CPC 422.2.1 may not need to apply to those spaces and we can make one of the rooms men's and the other women's (maybe?). Then we could put the urinal in the men's room and everyone's happy (assuming that doesn't conflict with CBC Ch11B / ADAS).

3. There is one restroom off the waiting room. Unisex single-user. Does the urinal need go in the toilet room accessible to the lobby? There is also a staff restroom (not accessible from the lobby) that the client has made very clear should not have the urinal in it.
 
Unisex single-user. Does the urinal need go in the toilet room accessible to the lobby?
I would say yes it should be in that one.

Not being in California I can't provide you with a response to the 1st two questions. However, if you were in Montana as a building official, I can work with you and come up with a solution that meets the intent of the code without meeting the specific wording of the code.

(32) The building official may waive minor building code violations that do not constitute an imminent threat to property or to the health, safety, or welfare of any person.
 
2022 CBC
[A] 104.10 Modifications
Where there are practical difficulties involved in carrying out the provisions of this code, the building official shall have the authority to grant modifications for individual cases, upon application of the owner or the owner's authorized agent, provided that the building official shall first find that special individual reason makes the strict letter of this code impractical, the modification is in compliance with the intent and purpose of this code and that such modification does not lessen health, accessibility, life and fire safety or structural requirements. The details of action granting modifications shall be recorded and entered in the files of the department of building safety.


I would suggest that you put together a proposal to the building official to formally request a modification to the requirements of code. In that proposal you should outline the owners request in such a way that it frames them as practical difficulties, clearly show that the modification is in compliance with the intent of the code, and that it does not lessen health, accessibility, life and fire safety or structural requirements.

I would suspect that a BO is not going to do all this work for you, and is not going to just approve it without this on file, it's a CYA kind of thing.
 
I agree with Joe B. - - do a modification request. You have a functional reason very specific to the use of the facility that ought to be totally justifiable.
The building official may ask about water conservation, and maybe you throw him a bone with a dual-flush toilet.
 
This seems insane, however, I have been to several California restaurants with single-use unisex restrooms and they did not have urinals. So someone is getting around this code.
 
This seems insane, however, I have been to several California restaurants with single-use unisex restrooms and they did not have urinals. So someone is getting around this code.
I believe that there is a specific exception in CPC / UPC for A and E occupancies that allows you to eliminate the urinal in certain situations. Unfortunately, that exception does not apply to B occupancies, at least as far as I have seen (although I'm hoping someone can point me to an exception that does apply to B).
 
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