Door landing (2018 IBC 1010.1.6) @ upper floor dwelling unit bathroom

[tcoon]

Hi All,

Working on an apartment building (R-2) - upper floors, so no accessibility issues - and I have a plan reviewer requiring a "landing" on the interior of dwelling unit bathroom doors, based on Section 1010.1.6. It's a 30" wide door, and there's no problem with the width, but reviewer is requiring 36" deep clear space on the interior of the door. It's not a small bathroom overall (about 5' x 9'-6", including vanity and tub), but at the moment, that 36" deep, straight in from the door, overlaps the front of the toilet a bit.

Am I missing an exception or definition somewhere that might address this, similar to door widths, etc.? I could be wrong - this reviewer definitely knows the code - but I haven't ever applied that "landing" section in a situation like this, and it's never come up before.

 

[Paul Sweet]

Only if it's on a stair or ramp.

 

[SH225]

The maneuvering space at a door is not a landing. The level surface at the top or bottom of a stairway or ramp is a landing. The landing could occur at a door, in which case section 1010.1.6 would apply.

 

[tcoon]

Thanks. Is "landing" defined that way anywhere in the code that you're aware of - as being related to a stairway or ramp? I agree completely, and it makes total sense that that's what a landing really "is" - he's just not finding anything that officially defines it for him, so he's saying 1010.1.5 requires a "floor or landing" on each side of a door, and he's considering those as 2 words describing the same thing - a "spot." And then 1010.1.6 defines the required dimensions of that "spot".

Other than our common English language understanding of "landing", I can't find anything that separates it from just "floor".

 

[SH225]

Before I replied, I checked Google. The result is in the attachment. I also attached the result from Merriam-Webster, which says it's the level part of a staircase.

 

[tcoon]

Thanks, SH Trust me, you don't have to convince me about the "common" definition - I have to convince him of a "code" definition.

Much appreciated.

 

[Yikes]

Can you clarify: is there a stairway riser immediately on the other side/face of the bathroom door? The word "landing" is typically associated with stairs (IBC 1011.6), as discussed above. There is no specific definition of "landing" in IBC chapter 2.
IBC 1010.1.1 xc. #8 says that in R-2 dwelling units, the minimum clear opening widths shall not apply to (nonaccessible) interior egress doors.

 

[Mr. Inspector]

Their are rules for landings at stairways and their different rules on landings at doors.

Stairways in in section 1011 where there is a section for landings at stairways.

This section is under section 1010 Doors, Gates and Turnstiles:

1010.1.6 Landings at doors. Landings shall have a width
not less than the width of the stairway or the door, whichever
is greater. Doors in the fully open position shall not
reduce a required dimension by more than 7 inches (178
mm). Where a landing serves an occupant load of 50 or
more, doors in any position shall not reduce the landing to
less than one-half its required width. Landings shall have a
length measured in the direction of travel of not less than
44 inches (1118 mm).
Exception: Landing length in the direction of travel in
Groups R-3 and U and within individual units of Group
R-2 need not exceed 36 inches (914 mm).

But I don't know of a section that says you can't have something in a door landing like a toilet.

 

[ICE]

Only if it's on a stair or ramp.

That's the answer you're looking for.

 

[tcoon]

Yikes: No stairs or elevation change of any kind near the door - bathroom on one side, and a normal dwelling unit hallway on the other. He's okay with reducing the width of the door, just not the depth of what he's calling a "landing" on either side.

Rick: That's been my understanding - that there are code requirements regarding landings and how they relate to their stairways/ramps (10.11.6) ... and there are code requirements regarding landings and how they relate to doors that open near them (10.1.6) ... but the requirements are all regulating the landing's minimums, not the door's. I wouldn't disagree at all if the reviewer said I couldn't have a toilet on a stair/ramp landing - door or not, that makes sense (once you get past the general toilet on the landing part, that is).

ICE: I hear ya - and I agree with you. This reviewer knows the code better than most in my experience, but he is very literal in his readings. He knows a "landing" is typically something associated with a stair or a ramp, but he can't get past reading 10.1.6 as "Landings at DOORS", where "landing" just means "space", because there's no official definition - rather than "LANDINGS at doors", where you have to have the landing first, in order to regulate how a door interacts with it.

To be honest, I think he agrees with me, but needs something more official to get to accepting it as code-compliant. I appreciate the help, all, I'll keep at it.

 

[Yikes]

But I don't know of a section that says you can't have something in a door landing like a toilet.

The crux of the issue is whether there is such a thing as a "door landing". 1010.6 is titled Landings AT doors, not Landings FOR doors.
It appears that most commenters on this thread would understand "landings at doors" = "stair landings that happen to be at doors".

 

[tcoon]

Thanks, Yikes - agreed. I'm concentrating on trying to use the language outside the "landing" word to try and separate the two concepts with him. Something like 1012.6.5 regarding doors at ramp landings would have been helpful...

I did notice the definition of "flight" in Chapter 2 - "A continuous run of rectangular treads, winders or combination thereof from one landing to another." Even tho "landing" itself isn't defined, that seems an odd way to use the word if it's not stair-specific.

 

[Inspector Gift]

He may be helped by looking closely at the charging statement at the beginning of Section 1010, which says,

"1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section."

I would like to see the floor plan before jumping to a conclusion. But without seeing the floor plan, I would ask 3 questions:
1) Does the bathroom door serve as a means of egress?
2) If so, is the unit is a Type-B unit?
3) If not, then does section 1010.1.6 really apply to that specific bathroom door?

 

[tcoon]

Thanks, Inspector...
1) No more than any other bathroom door does - reviewer's position is that all doors from "occupiable" (vs. "occupied") spaces in the apartment are "means of egress" doors. Not sure I agree, but I don't have a big of problem with that part.
2) It's not a Type B - this is on second and third floor and all first floor units are Type B (or A) as required. In fact, the first floor bathroom below is larger in order to provide the clear floor spaces required for accessibility.
3) It does according to him, because of 1) above.

 

[Inspector Gift]

Thanks, Inspector...
1) No more than any other bathroom door does - reviewer's position is that all doors from "occupiable" (vs. "occupied") spaces in the apartment are "means of egress" doors. Not sure I agree, but I don't have a big of problem with that part.
2) It's not a Type B - this is on second and third floor and all first floor units are Type B (or A) as required. In fact, the first floor bathroom below is larger in order to provide the clear floor spaces required for accessibility.
3) It does according to him, because of 1) above.

It is my understanding that residential bathrooms are NOT considered HABITABLE SPACE, and, as such, are not included as part of the required means of egress.

Ask your plan reviewer read the definitions for "HABITABLE SPACE." and "OCCUPIABLE SPACE" as found in Chapter 2.

Then ask you plan reviewer if he requires a landing on both sides of all closet doors, since anyone can stand inside an empty closet and "occupy" the area in the closet.

IF he still remains unchanged, then appeal to the Building Official.

PS: can you post a picture or illustration of the floor plan in question?

 

[SH225]

What would you do to solve it if you can’t convince the plans examiner? Practically everything I see either has the door in front of the vanity or 3 feet in front of the water closet, and usually both.

 

[tcoon]

Inspector: I'll work on the plan image - can't quite remember how to do it on here...
He's also referred to the "means of egress" definition, which references egressing from "every room and usable space" - I expect he doesn't include a normal depth closet as one of those. FWIW, I could totally appeal it, but I try to avoid doing that unless I have to. I have to work with him on this building and many more down the road - I'm just in "friendly convincing" right now.

SH: I can solve it if I have to - I've got room to move the door and wall - but it puts an extra "bump" in the room, which I'd prefer to avoid if I can.

 

[Yikes]

Think of all the commercial restrooms out there with toilet compartments that are 30" wide. If that compartment is a "usable space" per the IBC then how did it get approved with such a narrow "means of egress"?

Maybe there's another way to pry the building official away from chapter 10. Feel free to poke holes in this line of thinking - - I'm just spitballin' here.
Let's look at whether the bathroom door is covered under the requirement of IBC chapter 10. First, look at IBC 202 definition of EXIT ACCESS DOORWAY. "A door or access point along the path of egress travel from an occupied room, area or space where the path of egress enters an intervening room, corridor, exit access stairway or ramp."

So, the bathroom door is covered by IBC Chapter 10 only if the bathroom is considered an occupied room, area, or space.

Now, let's look at IBC 202 definition of OCCUPIABLE SPACE. "A room or enclosed space designed for human occupancy in which individuals congregate for amusement [no], educational [no] or similar purposes [no] or in which occupants are engaged in labor [no, and no potty jokes, please], and which is equipped with means of egress and light and ventilation facilities meeting the requirements of this code."

So, the bathroom does not meet the definition of an occupiable space, and therefore the bathroom door does not meet the definition of "exit access doorway".
Note also that IBC 1004.5 does not have any occupant load for a bathroom.

I know I'm stretching it a bit here, but the point is not to eliminate safe exiting from a bathroom; the point is to shake the building official's certainty that a bathroom door is required by code to have a 36" deep "landing".

 

[Mr. Inspector]

I also believe that landings are only for stairways. In my post i argued the opposite to see what others would say. It seems to be that if this section was under stairways and ramps instead of doors and/or a definition of "landing" it would make more sense in the code.

 

[tcoon]

Had a little more conversation this morning with the reviewer... We're not in a hurry about it, so it's a slow conversation, via email. He shared these from the commentary for 1010.1.6:

"Door landings are at either side of the door. Landings can overlap floor surfaces within a room or corridor, overlap an exterior porch or balcony, or share the landings for stairways."
and...
"No matter what size the door or stair landing is, door landings are to have the floor elevation requirements of Section 1010.1.5 extending at least 44 inches (36" per exception, in our case) in the direction of egress travel."

So I'm having a hard time disagreeing that a "door landing" is its own thing, possibly separate from a "stair landing". And despite the definition of "occupiable," he's adamant that the bathroom will be "occupied" by the dwelling unit residents for reasonable periods of time (unlike a closet or something). He even pointed out that the commentary's specific reference to toilet rooms NOT being occupiable, in older codes, has been removed in more recent codes.

My questions back noted that there are definitely allowances for the reduction of this required space by the door itself, at least, so maybe other things would follow that reasoning, and also wondered whether the "direction of egress travel" had to be perpendicular to the door. We'll see about those.

At this point, conversation is becoming more "informational" than anything. He was very up front about my appeal options, and as I said, the guy knows his codes and we get along well - this isn't confrontational in any way. In the end, I expect we'll make the room a little bigger and I'll file it under "things I think the code doesn't really mean, but kind of says."

I appreciate all the help - thanks!

 

[ADAguy]

So why then why is the space (landing?) between the lip of the toilet bowl and the stall door (in swinging or not) allowed to only be 24"?

 

[tcoon]

Wish I had an answer for you, ADAguy. I expect he would make a distinction between a stall and a “space”. I’ll be asking about that in the next round, tho.

 

[Yikes]

Curious what he would say about a 60" deep toilet stall, which with almost all accessible toilets would leave less than a 36" deep "landing" inside his interpretation of the "occupiable space" of the toilet stall... and yet there it sits, right in the code:

 

[ADAguy]

And they are often all "occupied" spaces.