Lavatory Requirements per Table 2902.1

[Billygoat91]

We have a site that will be used for RV and boat storage with an 1800 SF storage warehouse with 6 units. All of these units, including parking spaces for vehicle storage, will be used for temporary storage, with users dropping off and picking up vehicles. The municipailty that is handling permitting wants one bathroom and sink installed per table 2902.1 in the IBC; however, I feel as if storage, as described in the table, does not necessarily pertain to the proposed use of this property.

Is there anything in the code that excludes a rented RV and boat storage facility from the public bathroom requirement laid out in table 2902.1?

Thank you for the help!

 

[ADAguy]

! here it depends on local control. Storage units by their nature do not usually require public RR's. If provided they must then comply.

 

[classicT]

In WA, we have an exception for unoccupied buildings.

However, it looks like TN has a state amended IBC that refers to the IPC. I do not see an exception on first look.

 

[classicT]

Check out TN IPC Section 403

 

[Yikes]

If the storage warehouse is used exclusively as vehicular storage, i.e. it is a parking garage, then it would not match the description of item #8 in TN IPC Table 403.1 and therefore there would be no fixtures required. But if your certificates of occupancy allow for the possibility of the kind of storage described below, then yes they are correct to require the plumbing fixtures.

 

[classicT]

If the storage warehouse is used exclusively as vehicular storage, i.e. it is a parking garage, then it would not match the description of item #8 in TN IPC Table 403.1 and therefore there would be no fixtures required. But if your certificates of occupancy allow for the possibility of the kind of storage described below, then yes they are correct to require the plumbing fixtures.

View attachment 8328

I disagree with the indication that if the description does not match, then fixtures are not required. That is neither code based, nor in-line with common practice.

As per the lead in code section to TN IPC Table 403.1, TN-IBC Section 2909.1 is as follows. Specifically note that types of occupancies not listed in the table, shall be considered individually by the BO. It is therefore up to the BO.

[P] 2902.1 Minimum Number of Fixtures​

Plumbing fixtures shall be provided for the type of occupancy and in the minimum number shown in Table 2902.1. Types of occupancies not shown in Table 2902.1 shall be considered individually by the building official. The number of occupants shall be determined by this code. Occupancy classification shall be determined in accordance with Chapter 3.​

Given that the BO (or his/her staff) have already provided a correction notice indicating that they believe fixtures are required, the road appears to lead towards providing the fixtures. That is, unless you can appeal to the BO's judgement and ask for an exemption, which to BO is allowed to grant.

 

[Billygoat91]

If the storage warehouse is used exclusively as vehicular storage, i.e. it is a parking garage, then it would not match the description of item #8 in TN IPC Table 403.1 and therefore there would be no fixtures required. But if your certificates of occupancy allow for the possibility of the kind of storage described below, then yes they are correct to require the plumbing fixtures.

View attachment 8328

Thank you all for your responses. Unfortunately, the municipality is regarding "storage" in a more general sense. The site will only be used for vehicular storage where tenants/rentees will rent a space to store their RVs and boats in a covered barn or open air parking lot. We have included a small storage warehouse where vehicles can be stored in a garage type structure. It seems that we will have a hard time getting out of "the storage of goods" language in that table

 

[mtlogcabin]

1800 SF storage warehouse with 6 units. All of these units, including parking spaces for vehicle storage, will be used for temporary storage, with users dropping off and picking up vehicles.

There are no plumbing fixture requirements for a "U" occupancy

If the building is limited to vehicle storage and you construct a one-hour fire barrier between the 6 units and your lease agreements spells out that it is strictly storage of the vehicle then the Rest Room is not required because it is a "U" occupancy.

[BG] PRIVATE GARAGE. A building or portion of a building in which motor vehicles used by the owner or tenants of the building or buildings on the premises are stored or kept, without provisions for repairing or servicing such vehicles for profit.

SECTION 312
UTILITY AND MISCELLANEOUS GROUP U

312.1 General.
Buildings and structures of an accessory character and miscellaneous structures not classified in any specific occupancy shall be constructed, equipped and maintained to conform to the requirements of this code commensurate with the fire and life hazard incidental to their occupancy. Group U shall include, but not be limited to, the following:

Carports

Private garages


406.3.1 Classification.
Private garages and carports shall be classified as Group U occupancies. Each private garage shall be not greater than 1,000 square feet (93 m2) in area. Multiple private garages are permitted in a building where each private garage is separated from the other private garages by 1-hour fire barriers in accordance with Section 707, or 1-hour horizontal assemblies in accordance with Section 711, or both.



[P] 2902.3 Employee and public toilet facilities.
For structures and tenant spaces intended for public utilization, customers, patrons and visitors shall be provided with public toilet facilities. Employees associated with structures and tenant spaces shall be provided with toilet facilities. The number of plumbing fixtures located within the required toilet facilities shall be provided in accordance with Section 2902 for all users. Employee toilet facilities shall be either separate or combined employee and public toilet facilities.

Exception: Public toilet facilities shall not be required for:

1. Parking garages where operated without parking attendants.

[P] 2902.1 Minimum number of fixtures.
Plumbing fixtures shall be provided in the minimum number as shown in Table 2902.1 based on the actual use of the building or space. Uses not shown in Table 2902.1 shall be considered individually by the code official.

 

[classicT]

There are no plumbing fixture requirements for a "U" occupancy

If the building is limited to vehicle storage and you construct a one-hour fire barrier between the 6 units and your lease agreements spells out that it is strictly storage of the vehicle then the Rest Room is not required because it is a "U" occupancy.

[BG] PRIVATE GARAGE. A building or portion of a building in which motor vehicles used by the owner or tenants of the building or buildings on the premises are stored or kept, without provisions for repairing or servicing such vehicles for profit.

SECTION 312
UTILITY AND MISCELLANEOUS GROUP U

312.1 General.
Buildings and structures of an accessory character and miscellaneous structures not classified in any specific occupancy shall be constructed, equipped and maintained to conform to the requirements of this code commensurate with the fire and life hazard incidental to their occupancy. Group U shall include, but not be limited to, the following:

Carports

Private garages


406.3.1 Classification.
Private garages and carports shall be classified as Group U occupancies. Each private garage shall be not greater than 1,000 square feet (93 m2) in area. Multiple private garages are permitted in a building where each private garage is separated from the other private garages by 1-hour fire barriers in accordance with Section 707, or 1-hour horizontal assemblies in accordance with Section 711, or both.



[P] 2902.3 Employee and public toilet facilities.
For structures and tenant spaces intended for public utilization, customers, patrons and visitors shall be provided with public toilet facilities. Employees associated with structures and tenant spaces shall be provided with toilet facilities. The number of plumbing fixtures located within the required toilet facilities shall be provided in accordance with Section 2902 for all users. Employee toilet facilities shall be either separate or combined employee and public toilet facilities.

Exception: Public toilet facilities shall not be required for:

1. Parking garages where operated without parking attendants.

[P] 2902.1 Minimum number of fixtures.
Plumbing fixtures shall be provided in the minimum number as shown in Table 2902.1 based on the actual use of the building or space. Uses not shown in Table 2902.1 shall be considered individually by the code official.

I disagree.

[BG] PRIVATE GARAGE. A building or portion of a building in which motor vehicles used by the owner or tenants of the building or buildings on the premises are stored or kept, without provisions for repairing or servicing such vehicles for profit.

As you noted, Private Garages may be classified as group U. That said, these types of structures (storage complexes for RV's, boats, etc.) are not typically occupied by the owner or tenant.

This is an S-1 occupancy.

 

[mtlogcabin]

these types of structures (storage complexes for RV's, boats, etc.) are not typically occupied by the owner or tenant.

Everyone who rents a space for their RV, boat, car, etc. or leaves it empty and never occupies or puts anything in the space is a tenant.

Essential Meaning of tenant
: a person, business, group, etc., that pays to use another person's property :

 

[Tim Mailloux]

Everyone who rents a space for their RV, boat, car, etc. or leaves it empty and never occupies or puts anything in the space is a tenant.

Essential Meaning of tenant
: a person, business, group, etc., that pays to use another person's property :

If I pay to leave my car in a parking gaage for the day (also an S-1 occupancy BTW) does that make me a tenant?

 

[Tim Mailloux]

ten·ant
/ˈtenənt/

noun
noun: tenant; plural noun: tenants

1. a person who occupies land or property rented from a landlord.

 

[mtlogcabin]

not typically occupied by the owner or tenant.

There are only 3 different types of occupants of a piece of property. An owner, a tenant and a squatter and I don't believe the 3rd would be legal or referenced in the code

2018 IPMC
TENANT. A person, corporation, partnership or group, whether or not the legal owner of record, occupying a building or portion thereof as a unit.

Your example of leaving your car in a parking garage for a day (S-1) still would not require a restroom if there is no attendant onsite

The fixture plumbing Table for S-1 occupancies is a general requirement. Section 2902.3 is a specific requirement for parking garages with no attendants.

2018 IBC & IPC

[A] 102.1 General.
Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable.

[P] 2902.3 Employee and public toilet facilities.
For structures and tenant spaces intended for public utilization, customers, patrons and visitors shall be provided with public toilet facilities. Employees associated with structures and tenant spaces shall be provided with toilet facilities. The number of plumbing fixtures located within the required toilet facilities shall be provided in accordance with Section 2902 for all users. Employee toilet facilities shall be either separate or combined employee and public toilet facilities.

Exception: Public toilet facilities shall not be required for:

1. Parking garages where operated without parking attendants.