Recessed toilet paper dispenser vs. grab bar clearance

[Yikes]

CBC 11B-609.3 and ADA 609.3 says that in toilet facilities, the space between the wall and the grab bar shall be 1 1/2 inches (38 mm).

This dimension is absolute, not a minimum or a maximum.

Question #1: Are there any construction tolerances allowed?

Question #2: there are many toilet paper / seat cover dispensers, such as this one from Bobrick, that claim to be ADA accessible when mounted behind a grab bar. In this case, there is a 3/16" mounting flange. Does that make it impossible to meet ADA, since the space between the bar and the wall would now be 1 5/16" instead of 1 1/2"?

 

[jdfruit]

Tolerance allowed but there is no published trade or professional standard known applicable to the condition. Talked this over with Bobrick about 5 years ago and the result is "?" for tolerance. Claim that product is accessible is "caveat emptor".

 

[Yikes]

jdfruit, it would seem to me that the goal would be to have minimum clearance of 1 1/2". What would be the harm if a grab bar had 1 3/4" clearance from the wall? But no, the code wants both minimum and maximum: absolute 1 1/2".

Why??

 

[Msradell]

Obviously none of us know exactly what the powers that be were thinking when they wrote the requirement but my thought is that possibly that if it's too wide it would be possible to get your arm wedged behind it. Kind of like the maximum spacing of balusters so the youngster can't fall through them. Obviously you don't want to close either so you have room to get your hand around it. Just a guess on my part but....

 

[Yikes]

Obviously none of us know exactly what the powers that be were thinking when they wrote the requirement but my thought is that possibly that if it's too wide it would be possible to get your arm wedged behind it. Kind of like the maximum spacing of balusters so the youngster can't fall through them. Obviously you don't want to close either so you have room to get your hand around it. Just a guess on my part but....

Msradell, I appreciate trying to take a stab at the rationale behind it. I wondered about that too. But then I see at other handrail situations, such as at a stair handrails, (CBC 11B-505.5), the 1.5" clearance is listed as a MINIMUM.

So if "minimum" works at a stair, why wouldn't it also work at a toilet stall?

 

[JPohling]

Msradell, I appreciate trying to take a stab at the rationale behind it. I wondered about that too. But then I see at other handrail situations, such as at a stair handrails, (CBC 11B-505.5), the 1.5" clearance is listed as a MINIMUM.

So if "minimum" works at a stair, why wouldn't it also work at a toilet stall?

And the Minimum 1.5" is relatively new. 2011 it was 1.5" exactly, no deviation. I have previously had several handrails modified to comply with the 1.5" exactly code language for accessibility compliance. Thankfully I will not have to do that again.

 

[mark handler]

David Kent Ballast, FAIA, in his book Handbook of Construction Tolerances: 2nd Edition, offers many well-researched and thoughtfully-analyzed opinions about what numbers he believes should be considered acceptable for a wide variety of construction materials and methods. In lawsuits that the Department of Justice has filed, DOJ has taken the position that tolerances cannot be predefined but must always be considered on a case-by-case basis considering the design, the materials and methods, and the specific field conditions. The California State Attorney General’s office has taken the same position. The conditions that result from that approach will vary from case to case.

 

[mark handler]

https://www.access-board.gov/research/completed-research/dimensional-tolerances/introduction

The Access Board

Accessibility standards reference industry guidance in the measure of field and construction tolerances.

 

[Yikes]

Thanks, Mark. Those references will be useful for other aspects of the project, even if they don't address this particular situation.

I do note that the code requirement states "1 1/2 inches (38mm)". However 1.5 inches is actually 38.1 mm.

So if nothing else, we know that the code itself technically has some wiggle room, as its mathematical tolerances are only accurate to within +/- 0.1 mm.