Requirement for toilet rooms between two tenants.

[Fast_Edd1e]

I have a project where we have separate retail spaces that only require 1 toilet room for the occupant count. 1,620sf allowing for 27 occupants. Under 50 only require 1 toilet room since we don't need separate facilities.

Now the owner is wanting to subdivide that 1620sf into two tenants and have a common toilet and janitor closet. Both are still going to be mercantile. But do i need to provide an additional toilet just because its another tenant? Or can i used the combined mercantile space for the occupant count? I attached a sketch.

 

[classicT]

I don't see an issue with what you are proposing, at least initially. I'd be willing to bet that down the road one of the spaces will convert to a Group B, and when it does, the exception for a single restroom in Group M would be invalid. So, not a code issue, but perhaps a design issue.

The other aspect I would start to consider is how you will control access. If one store is open and the other closed, how is security handled to the restrooms? You cannot have locks that would impede egress, nor would your customer want the adjoining tenant to have access to their space when closed.

One other aspect to consider, which I have encountered before, is who pays for restroom supplies and handles the cleaning? Will both tenants dedicate the same level of funding/effort to those respective tasks? Is the customer/staff use of the facilities equal? Sharing a restroom inevitably leads to a disagreement between the tenants.

 

[Yankee Chronicler]

ClassicT brings up several good points. My immediate reaction was that the proposed layout meets code, but I also wondered how access will be controlled. What if one store closes at 8:00 p.m. and the other store is open until 10:00 p.m.? Those doors between the individual tenant spaces and the common space serving the toilet room can't be locked, from either direction. When people are in either space, they have to have access to the toilet room, and when anyone is in the toilet room or the common vestibule, they have to have access to the exits.

 

[Fast_Edd1e]

ClassicT brings up several good points. My immediate reaction was that the proposed layout meets code, but I also wondered how access will be controlled. What if one store closes at 8:00 p.m. and the other store is open until 10:00 p.m.? Those doors between the individual tenant spaces and the common space serving the toilet room can't be locked, from either direction. When people are in either space, they have to have access to the toilet room, and when anyone is in the toilet room or the common vestibule, they have to have access to the exits.

Thank you. The owner is looking alot at electronic access control with key fobs and such. So that might sort some of the locking logistics. But i brought up the question on who is going to clean, supply, that shared space. Unless he is planning on hiring a company to manage the whole building.

 

[Yankee Chronicler]

Hiring a cleaning company is another logistical nightmare, because the only access to the common spaces is through the tenant spaces. I doubt any merchant is going to be happy about allowing a crew of minimum wage cleaners to have access to their store after hours.

Beyond that, access control with key fobs may work for getting people into the toilet room, but be sure you look very carefully at requirements for egress. The starting point in the codes (building and fire) is that egress doors have to be operable from the egress side at all times. Yes, there are some provisions that allow for delayed egress or controlled egress, but that's only under certain circumstances and where a laundry list of criteria are satisfied.

It occurs to me that the money the landlord would spend on fancy electronic locks and access control could be better spent on just making a second toilet room. That way, the rentable tenant spaces will be larger. As proposed, the common vestibule, toilet room, janitor's closet and storeroom are common space, so not included in the net rentable area.

 

[classicT]

Thank you. The owner is looking alot at electronic access control with key fobs and such. So that might sort some of the locking logistics. But i brought up the question on who is going to clean, supply, that shared space. Unless he is planning on hiring a company to manage the whole building.

Cannot do that... MoE doors, which these would be included within, cannot require the use of a key or special knowledge.

2018 IBC 1010.1.9 Door Operations​

Except as specifically permitted by this section, egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort.

 

[Fast_Edd1e]

Cannot do that... MoE doors, which these would be included within, cannot require the use of a key or special knowledge.

2018 IBC 1010.1.9 Door Operations​

Except as specifically permitted by this section, egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort.

Thank you. After I responded to the earlier comment I understood the egress issues from that space. Those back retail doors would probably need panic hardware on them since there is no other egress. Which would negate any securing of the doors.

I'm going to push for a shared corridor layout that both retail will access from. Sorta like the attached.

 

[Yankee Chronicler]

No, they don't require panic hardware. They can be paddle-operated latches, or they can be conventional locksets with lever handles. The point is that they can't be locked against egress travel at any time there are people on the egress side of the doors unless that meets several very specific criteria buried in section 1010.2 of the IBC. I don't think a mercantile situation such as this fits any of the criteria allowing such locking.

This new plan addresses egress from the toilet room, but it drastically reduces the net rentable area of both stores. It also creates a security issue, especially for the store on the right. You now have an unlocked rear door at the very back of the store, that any shoplifter can just walk out through with an armload of pilfered product.

I assume you are the architect? Why not look at the direct solution -- taken that supply closet of whatever it is, combine it with the janitor's closet, and make a second unisex toilet room to serve the space on the left? That way each tenant gets a toilet room, and there's no reduction in the net rentable area of the overall space because each tenant's space will include the toilet room serving that space. Once you establish a common corridor, that's lost rental space -- it costs the landlord $$$ every single month going forward.