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Required Restrooms - ADA + Gender Neutral/Unisex + Employee

O

oflass

Registered User
Joined
Oct 28, 2022
Messages
3
Location
LA, California
I'm working on a restaurant/bar layout with approx. 300 seats in LA County. The 2021 IPC/IBC calculator is telling me that we need 2 WCs for men and 2 for women -- it doesn't seem we have space to do full ADA-compliant multi-user restrooms (based on desired layout), and it sounds like with both single- and multi-user restrooms, all must be compliant, so even less an option.

I'm wondering if with California's unisex restroom law, will we be compliant with 4 clustered single-user restrooms? Of these, it sounds like only 2 need to be fully ADA-accessible (https://www.access-board.gov/ada/guides/chapter-6-toilet-rooms/#clustered-single-user-toilet-rooms/). Am I misunderstanding this?

As a followup, for employee restrooms, we're considering trying to locate them in a small mezzanine accessible through the kitchen area. To what degree will these need to be accessible? Obviously, no one in a wheelchair is getting up to the mezzanine, so I'm a bit confused by the requirements here.

Thanks!
 
Welcome to the forum!
Questions/comments:
1. You did not say if this is a new building, or an existing building undergoing alteration, or a historic building.
2. If you are submitting plans for first plan check prior to 1/1/2023, you should be using the 2019 codes, not the 2021 codes. The 2019 California Plumbing Code (CPC) is based on the 2018 Uniform Plumbing Code, not the IPC.
3. You did not say what your original fixture count was based upon. You mentioned 300 seats, but the CPC is based on building area, not number of seats.
422.1 Fixture Count​
Plumbing fixtures shall be provided for the type of building occupancy and in the minimum number shown in Table 422.1 [OSHPD 1, 2, 3, 4 & 5] and Tables 4-2 and Table 4-3. The total occupant load and occupancy classification shall be determined in accordance with the California Building Code [DSA-SS & DSA-SS/CC] or Occupant Load Factor Table A. Occupancy classification not shown in Table 422.1 shall be considered separately by the Authority Having Jurisdiction.​
If after using that procedure your calculated occupant load was still 300 people (150 male / 150 female), then the CPC Table 422.1 would indicate:​
  • Women: 4 toilets, 2 lavs
  • Men: 2 toilets, 1 urinal, 1 lav
On that basis, I do not see how 4 single user rooms will add up to that quantity of fixtures.​
4. Yes, when you have multiple single-user toilet rooms clustered in a single location, 50% of those rooms need to be accessible per CBC 11B-213.2 exc. #4.
5. If the employee restroom is the only restroom allowed to be used by employees, then yes it must be accessible and on an accessible route. A restaurant could have an employee in a wheelchair (example: host or hostess).
 
oflass said:
I'm wondering if with California's unisex restroom law, will we be compliant with 4 clustered single-user restrooms? Of these, it sounds like only 2 need to be fully ADA-accessible (https://www.access-board.gov/ada/guides/chapter-6-toilet-rooms/#clustered-single-user-toilet-rooms/). Am I misunderstanding this?

As a follow-up, for employee restrooms, we're considering trying to locate them in a small mezzanine accessible through the kitchen area. To what degree will these need to be accessible? Obviously, no one in a wheelchair is getting up to the mezzanine, so I'm a bit confused by the requirements here.

Thanks!
Click to expand...
RE: accessible restroom numbers
11B-213.2 Toilet Rooms and Bathing Rooms
Where multiple single user portable toilet or bathing units are clustered at a single location 5 percent, but no fewer than one, of the toilet units and bathing units at each cluster shall comply with Section 11B-603.

RE: Employee Restroom
11B-213.2 Toilet Rooms and Bathing Rooms
Where toilet rooms are provided, each toilet room shall comply with Section 11B-603.
 
Thanks both! I'm pretty new to the game, so this is hugely helpful.
1. It's a relatively new building envelope being fitted out for the first time - already constructed envelope, so I'm assuming it qualifies as "undergoing renovation", but not to the extent where anything would be considered "technically infeasible".
2. Thank you for pointing this out.
3. I think I'm still in the ballpark of 101-200 per sex for max occupancy with the area calculation (the plan is... mercurial, hence the ballparking), so it sounds like we'll definitely need to add 2 single-user rooms. Sounds like I'm now looking at 6 public single-user toilet rooms, each with its own lav; 3 of them will be fully wheelchair-accessible, and the other 3 will include urinals for fixture count + convenience?
 
oflass said:
1. It's a relatively new building envelope being fitted out for the first time - already constructed envelope, so I'm assuming it qualifies as "undergoing renovation", but not to the extent where anything would be considered "technically infeasible".
Click to expand...
Yikes said:
2. If you are submitting plans for first plan check prior to 1/1/2023, you should be using the 2019 codes, not the 2021 codes. The 2019 California Plumbing Code (CPC) is based on the 2018 Uniform Plumbing Code, not the IPC.
Click to expand...
Doesn't matter when the shell building was constructed, we have to assume you'll be submitting plans for your build-out. If those plans are submitted before the end of the year they are under the current CA code cycle. After the change of the year they will be reviewed under the new codes.
 
oflass said:
Sounds like I'm now looking at 6 public single-user toilet rooms, each with its own lav; 3 of them will be fully wheelchair-accessible, and the other 3 will include urinals for fixture count + convenience?
Click to expand...
At what point does that become impractical … 6 separate rooms? Vs 2 single rooms for accessibility and two 2 seaters?
 
steveray said:
A bathroom with a W/C and a urinal is likely not a single user bathroom....
Click to expand...
In California, it is still considered a single user restroom.

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160AB1732

"Article 5 (commencing with Section 118600) is added to Chapter 2 of Part 15 of Division 104 of the Health and Safety Code, to read:

Article 5. Single-User Restrooms​


118600.​

(a) All single-user toilet facilities in any business establishment, place of public accommodation, or state or local government agency shall be identified as all-gender toilet facilities by signage that complies with Title 24 of the California Code of Regulations, and designated for use by no more than one occupant at a time or for family or assisted use.
(b) During any inspection of a business or a place of public accommodation by an inspector, building official, or other local official responsible for code enforcement, the inspector or official may inspect for compliance with this section.
(c) For the purposes of this section, “single-user toilet facility” means a toilet facility with no more than one water closet and one urinal with a locking mechanism controlled by the user.
(d) This section shall become operative on March 1, 2017."
 
Folks have gone for centuries without Urinals, sit down or standup. the goal is still the same, elimination by a single person in a single room.
 
California: where a single restroom user can self-identify with plural pronouns, and a restroom with plural fixtures can identify as single-user.
 
Last edited:
Yikes said:
California: where a single restroom user can self-identify with plural pronouns, and a restroom with plural fixtures can identify as single-user.
Click to expand...
Next year somebody is going to be offended, and Calif will require restrooms marked “male” and “female” and “nonbinary” and “family” …
 
e hilton said:
At what point does that become impractical … 6 separate rooms? Vs 2 single rooms for accessibility and two 2 seaters?
Click to expand...

Unfortunately, I'm under the impression that the ADA says the multi-user rooms still need to be accessible, so there's no benefit in doing 2 singles + two 2-seaters compared to a larger 3-seater with an ADA stall. The 6 individual rooms, assuming 50% compliance, seem to give a little more flexibility in overall footprint, but I'm still sort of guessing about how to apply the "all single users are unisex" filter.

​

Required Compliance​

[§213]
...In new construction, access is required to all toilet rooms, including those for employees. However, where single user toilet rooms are clustered in one location, at least half for each use must comply (§213.2., Ex. 4).


Unisex (Single-Use or Family) Toilet Rooms​

[§213.2]

Where multi-user toilet rooms are provided, accessible unisex toilet rooms cannot serve as a substitute for access to multi-user rooms, except in alterations where making multi-user rooms comply is not technically feasible (§213.2, Ex. 1). Otherwise, where multi-user and unisex restrooms are provided, both types must comply.


ADAguy said:
Folks have gone for centuries without Urinals, sit down or standup. the goal is still the same, elimination by a single person in a single room.
Click to expand...
And for centuries, people have been sitting in someone's bad aim :rolleyes: Figure we might as well appeal to the lowest common denominator here.
 
e hilton said:
Next year somebody is going to be offended, and Calif will require restrooms marked “male” and “female” and “nonbinary” and “family” …
Click to expand...
That's NOT going to happen, CA law requires

Single-User Restrooms in California to Be Designated As All-Gender​

 
Here's a single fixture that identifies as plural... or maybe a plural fixture that identifies as single... anyway it's in California, in a public building, and it's over 100 years old:

Urinal.jpg
 
steveray said:
And that does not have the 60" clear for the W/C.....
Click to expand...
Spoiler Alert, it's an example of a urinal and toilet in same room.
The TP dispenser is also not per code, there is something in foreground....


Here is another single occupancy Toilet room with a "urinal"
Missing TP Holder, but they got the 60-inches
(Toilet flush "on wrong" side)

1668007409524.png
 
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