Door swing into clear space

[Sifu]

2017 ICC/ANSI 117.1, existing building:
Doors are not allowed to swing into the clear space of a fixture unless a clear floor space is provided beyond the arc of the door. The clear space can be at any angle. Clear space is permitted to include knee and toe space, and extend up to 25" under an element. Would the following comply for the exception for door swing into the clear space with the diagonal clear space extending under the lavatory? The red lines are mine. I think yes, but this feels very awkward, requiring the user to back in or turn around with the door open and then maneuver into a position under the lavatory to close the door before swinging around to back in beside the water closet. (when I write it out that way it feels even worse)

 

[Yankee Chronicler]

No.

 

[Sifu]

No.

I would cite code for a deficiency. I can't make a door swing citation since there is a clear space beyond the arc of the door per 603.2.2 #2. I can't make a clear space citation because there is a 30"x48" clear space per 305.3.2, I can't make a knee and toe clearance citation because it is permitted per 305.4, I can't cite knee and toe clearance under the lav per 306.2.2. What code would you reference for not permitting it? All of the illustrations in the ANSI standard show the clear space beyond the swing of the door, and at various angles, but none show that clear space under any elements. If they did it would be clear, or if they prohibited under the exc. for 603.2.2 it would be clear. This is a case where I may not like it, but I can't find a code to cite. And as you yourself have said, if a code can't be referenced, there is no violation. I happen to agree 100% with that philosophy, and apply it daily.

 

[Sifu]

The only thing I keep coming back to is clear space approach, but I think the side approach works as the user enters so that is a tenuous link.

 

[Mr. Inspector]

I am still on the 2009 ANSI and it looks like a very tight fit. If the knee space can get that close to the drain on the lavatory it complies to the 2009.

 

[Yankee Chronicler]

I would cite code for a deficiency. I can't make a door swing citation since there is a clear space beyond the arc of the door per 603.2.2 #2. I can't make a clear space citation because there is a 30"x48" clear space per 305.3.2, I can't make a knee and toe clearance citation because it is permitted per 305.4, I can't cite knee and toe clearance under the lav per 306.2.2. What code would you reference for not permitting it? All of the illustrations in the ANSI standard show the clear space beyond the swing of the door, and at various angles, but none show that clear space under any elements. If they did it would be clear, or if they prohibited under the exc. for 603.2.2 it would be clear. This is a case where I may not like it, but I can't find a code to cite. And as you yourself have said, if a code can't be referenced, there is no violation. I happen to agree 100% with that philosophy, and apply it daily.

You DON'T have a 30" x 48" clear space. Knee and toe projection beneath lavatories and countertops applies to approach/maneuvering space. It does not extend to the 30" x 48" clear floor space.

 

[steveray]

305.1 General​

A clear floor space shall comply with Section 305.

305.4 Knee and Toe Clearance​

Unless otherwise specified, clear floor space shall be permitted to include knee and toe clearance complying with Section 306.

 

[redeyedfly]

You DON'T have a 30" x 48" clear space. Knee and toe projection beneath lavatories and countertops applies to approach/maneuvering space. It does not extend to the 30" x 48" clear floor space.

Spoken like an inspector who assumes the code instead of actually reading it. Why are there so many of you?

 

[Sifu]

You DON'T have a 30" x 48" clear space. Knee and toe projection beneath lavatories and countertops applies to approach/maneuvering space. It does not extend to the 30" x 48" clear floor space.

Hmm, 305.4 & every single illustration seems to contradict that. What code would be cited for this violation? My first reaction was in agreement, and my comment was to provide the clear space beyond the arc, then I realized it is there, but under the sink. Totally agree it is clumsy, bit I don't have a code reference for that.

There is another question that comes up. This alteration is only to the toilet rooms. The original design had no accessibility, and this alteration is solely for increases in accessibility, so by the exception to IEBC 305.7 I wonder if any of the accessibility provisions can be called out (there are a few others). My conflict with that section is whether it applies only to the accessible route, and if it applies since the only upgrade is not an area of primary function.

 

[steveray]

I wonder if any of the accessibility provisions can be called out (there are a few others).

In theory...no....a lack of accessibility is not a building code violation unless it is WWOP....If they are doing voluntary upgrades, you don't necessarily get blanket upgrades...

And the bathrooms may be part of the area of primary function as far as the "upgrade" section is concerned:

306.7.1 Alterations affecting an area containing a primary function.​

Where an alteration affects the accessibility to, or contains an area of primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function.

 

[Yankee Chronicler]

Spoken like an inspector who assumes the code instead of actually reading it. Why are there so many of you?

I haven't assumed anything. Let's break this down, based on the 2009 A117.1:

Clear floor space is addressed in section 305. 305.3 establishes the size at 30" x 48". 305.4 says "Unless otherwise specified, clear floor space shall be permitted to include knee and toe clearance complying with Section 306."

Now we look at section 603.2.2 for doors in toilet and bathing room. The starting point is that doors may not swing into the clear space for any fixture. Then there are two exceptions. Exception #2 says "Where the room is for individual use and a clear floor space complying with Section 305.3 is provided within the room beyond the arc of the door swing, the door shall not be required to comply with Section 603.2.2."

The clear floor space is not clear space for a fixture; it is independent of fixtures. In fact, it is the provision that allows for door swing to overlap fixture clear space. You are apparently relying on 305.4. However, 305.4 is not a subparagraph to 305.3 -- it is a separate paragraph, of equal rank in the hierarchical structure. The exception to 603.2.2 specifically references 305.3 and does NOT mention 305.4. Therefore, as I read it, 305.4 does not apply.

You may choose to interpret it differently. We've been doing it this way for decades and you are the first person who has ever questioned it. These requirements go back at least as far as the 2003 edition of A117.1, so it's nothing new.

 

[Sifu]

In theory...no....a lack of accessibility is not a building code violation unless it is WWOP....If they are doing voluntary upgrades, you don't necessarily get blanket upgrades...

And the bathrooms may be part of the area of primary function as far as the "upgrade" section is concerned:

306.7.1 Alterations affecting an area containing a primary function.​

Where an alteration affects the accessibility to, or contains an area of primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function.

Bathrooms are absolutely an area of primary function for me, but not per the definition in the IEBC.

"....restrooms are not areas containing a
primary function."

The alteration is not affecting an area of primary function, because the toilets are not a primary function.

This particular code in the IEBC has flummoxed me before. I considered it to mean that the ROUTE to the bathrooms had to be upgraded, but not the bathrooms themselves. Others here and elsewhere, along with the commentary have disagreed. Yet, the definition of primary function does not include the bathrooms, so I wonder. FWIW, I require the toilet rooms to be upgraded when there is an alteration to an area of primary function, even though I may not agree with it based on these opinions. But I am not sure I can require every provision when the only alterations are to upgrade the toilets.

I got to use "flummoxed" today, so this conversation is a victory.

 

[Yankee Chronicler]

Bathrooms are absolutely an area of primary function for me, but not per the definition in the IEBC.

"....restrooms are not areas containing a
primary function."

The alteration is not affecting an area of primary function, because the toilets are not a primary function.

This particular code in the IEBC has flummoxed me before. I considered it to mean that the ROUTE to the bathrooms had to be upgraded, but not the bathrooms themselves. Others here and elsewhere, along with the commentary have disagreed. Yet, the definition of primary function does not include the bathrooms, so I wonder. FWIW, I require the toilet rooms to be upgraded when there is an alteration to an area of primary function, even though I may not agree with it based on these opinions. But I am not sure I can require every provision when the only alterations are to upgrade the toilets.

I got to use "flummoxed" today, so this conversation is a victory.

But when altering an area containing a primary function, the area containing the primary function and the accessible route to that area must be made accessible (subject to the 20% cost limitation). The definition of accessible route in this context includes the toilet rooms and drinking fountains serving the area containing the primary function. That's how you bring in the toilet rooms.

Does the toilet room in question serve an area containing a primary function? Given the size and the question, it's a private toilet room. If it's off a private office in an office building, then the office is an area containing a primary function. Is that office included in the alteration?

 

[Sifu]

I haven't assumed anything. Let's break this down, based on the 2009 A117.1:

Clear floor space is addressed in section 305. 305.3 establishes the size at 30" x 48". 305.4 says "Unless otherwise specified, clear floor space shall be permitted to include knee and toe clearance complying with Section 306."

Now we look at section 603.2.2 for doors in toilet and bathing room. The starting point is that doors may not swing into the clear space for any fixture. Then there are two exceptions. Exception #2 says "Where the room is for individual use and a clear floor space complying with Section 305.3 is provided within the room beyond the arc of the door swing, the door shall not be required to comply with Section 603.2.2."

The clear floor space is not clear space for a fixture; it is independent of fixtures. In fact, it is the provision that allows for door swing to overlap fixture clear space. You are apparently relying on 305.4. However, 305.4 is not a subparagraph to 305.3 -- it is a separate paragraph, of equal rank in the hierarchical structure. The exception to 603.2.2 specifically references 305.3 and does NOT mention 305.4. Therefore, as I read it, 305.4 does not apply.

You may choose to interpret it differently. We've been doing it this way for decades and you are the first person who has ever questioned it. These requirements go back at least as far as the 2003 edition of A117.1, so it's nothing new.

I have never seen one like this, so I have never had a need to question it. I see your point and my initial interpretation was the same, however when writing the comment and referencing a code I started thinking about the argument, and could not come up with the path you are using. I will try to digest it and see if I can come to the same conclusion. They also have a similar issue in the adjacent shower room, but there is no clear space anywhere beyond the arc of the door without hitting a wall so it is easier to cite.

Now I need to decide it IEBC 305.7 exempts it anyway.

 

[Yankee Chronicler]

305.7 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.

See my post #13.

 

[Sifu]

But when altering an area containing a primary function, the area containing the primary function and the accessible route to that area must be made accessible (subject to the 20% cost limitation). The definition of accessible route in this context includes the toilet rooms and drinking fountains serving the area containing the primary function. That's how you bring in the toilet rooms.

Does the toilet room in question serve an area containing a primary function? Given the size and the question, it's a private toilet room. If it's off a private office in an office building, then the office is an area containing a primary function. Is that office included in the alteration?

The toilet room is a private room, serving a day room on the lower level of a fire station. The day room is not being altered, nothing in the entire building is being altered, except 3 bathrooms. I would say the lower level day room is not an area of primary function, but even if it was, it is not being altered, and per 305.7 "where an alteration affects the accessibility to or contains an area of primary function", and per the definition of primary function specifically excluding the toilet rooms, I am not sure I can enforce the provisions they don't comply with. Now, it looks like the intent of the design is to provide accessible toilets, so in that intent I think I will make the comments. If they can comply, they should, but I'm not sure I can compel it.

I understand the path that is taken to compel upgrades to the toilet rooms when an alteration is made to an area of primary function, I just don't think the code as written supports it. It says "the route" to the area of primary function shall include toilets, not that the toilets must be upgraded. I take this to mean you must provide an accessible route to them, but unless the toilets are upgraded as part of the scope, they only must be provided with an accessible way to get t them. But I have conceded this point based on the commentary as providing the intent of the code and opinions such as yours. This has been debated before, and if an area of primary function was being done, I would go there.

 

[Inspector Gadget]

It's abundantly clear to me that very few designers actually think about what barrier-free access is all about.
Find someone in a wheelchair to talk to. They will almost certainly look at our diagram and ask a practical question: "Can I place my wheelchair to the side of that door, and then open it?"


I see designers miss door access inside bathrooms way the heck to often. See attached, which suffered a hearty cluster of "verily, thou shalt readeth thine Codes and fixeth thy plan" yesterday: different codes at play up here, but same issue, in that the bathroom door, once closed, can't be opened by someone in a wheelchair, and quite difficult for someone using a walker.

 

[Paul Sweet]

Do they really need a vanity the full width of the room instead of a wall hung lavatory?

 

[Sifu]

Do they really need a vanity the full width of the room instead of a wall hung lavatory?

That was my first thought, but it is just a top, no cabinets so there is space under it for the full width.

 

[Yikes]

It looks like at least one wall (with the door) is new. would you consider an alternate restroom layout something like this below, with 30x48 space shown in green, and the door moved down to one end of the restroom?

 

[steveray]

However, 305.4 is not a subparagraph to 305.3 -- it is a separate paragraph, of equal rank in the hierarchical structure. The exception to 603.2.2 specifically references 305.3 and does NOT mention 305.4. Therefore, as I read it, 305.4 does not apply.

I am going to respectfully disagree....Unless you want to agree that would also mean that 305.2 would not apply and we could slope the clear floor space? And maybe 305.6 and it would not be required to be on an accessible route? I get maybe not all of 305 needs to apply, but I think some of it does....

 

[Mr. Inspector]

You not doing anything in the area of primary function, so section 306.7.1 does not need to be used.
But if you are altering an area of primary function, any work in the toilet rooms can be part of 20% cost of the accessible route. Accessibly is strictly enforced in PA and our inspections are audited by the state and this is what we go by.

 

[redeyedfly]

I haven't assumed anything. Let's break this down, based on the 2009 A117.1:

Clear floor space is addressed in section 305. 305.3 establishes the size at 30" x 48". 305.4 says "Unless otherwise specified, clear floor space shall be permitted to include knee and toe clearance complying with Section 306."

Now we look at section 603.2.2 for doors in toilet and bathing room. The starting point is that doors may not swing into the clear space for any fixture. Then there are two exceptions. Exception #2 says "Where the room is for individual use and a clear floor space complying with Section 305.3 is provided within the room beyond the arc of the door swing, the door shall not be required to comply with Section 603.2.2."

The clear floor space is not clear space for a fixture; it is independent of fixtures. In fact, it is the provision that allows for door swing to overlap fixture clear space. You are apparently relying on 305.4. However, 305.4 is not a subparagraph to 305.3 -- it is a separate paragraph, of equal rank in the hierarchical structure. The exception to 603.2.2 specifically references 305.3 and does NOT mention 305.4. Therefore, as I read it, 305.4 does not apply.

You may choose to interpret it differently. We've been doing it this way for decades and you are the first person who has ever questioned it. These requirements go back at least as far as the 2003 edition of A117.1, so it's nothing new.

That is a ridiculous reach. 603.2.2 says the CFS has to be "in the room". 305.4 is a general clarification and certainly applies. This is a very common design strategy for tight restrooms.

 

[Yankee Chronicler]

That is a ridiculous reach. 603.2.2 says the CFS has to be "in the room". 305.4 is a general clarification and certainly applies. This is a very common design strategy for tight restrooms.

I won't dignify that with a response.