Separate facilities

[Sifu]

Is the exception to separate facilities for B occupancies of 25 or less intended to be used for small assembly that falls within the B but the use is assembly. Is a restaurant with 25 OL allowed to have one fixture.

 

[JPohling]

California would allow up to 50 occupants to be served by a single occupancy toilet in a M or B. restaurant uses included. 422.2 (3)

 

[fatboy]

I would allow it.

4. Separate facilities shall not be required in business
occupancies in which the maximum occupant
load is 25 or fewer.

303.1.1 Small buildings and tenant spaces. A building
or tenant space used for assembly purposes with an occupant
load of less than 50 persons shall be classified as a
Group B occupancy.

 

[Sifu]

To me this is an example of poor code, specifically the use of italics and conflating terms. The exceptions refer to "occupancies" as italicized in one exception, but not the other, but "occupancies" is not defined. Table specifies actual use, not occupancies, but then uses the occupancy classifications from the IBC. This question came to me from another AHJ, and I answered it the way I do it, but can't really point to a specific to justify it. I allow it, which is what I told them. The question is whether the exceptions intend to apply to use (as specified by 403.1 to use in the table) or classification (as implied by the use of the IBC terms in the table and the exceptions) but a case could be made both ways. If going with use, then the exception would not apply, if going by classification, then it would.

 

[Sifu]

The "business occupancies" exception was added in the 2018 code. The code change proposal offers only that it is proposed because sometimes the two separate facilities can be located at opposite ends of the tenant space causing unnecessary travel for one of the sexes.

Not making that up, just reporting on it. I can only shake my head.

 

[ICE]

Ask any woman her opinion on sharing a toilet with men. There was no women on that committee. The men must have been single.

 

[Sifu]

Ask any woman her opinion on sharing a toilet with men. There was no women on that committee. The men must have been single.

Quite the opposite, it was a woman that proposed it. I expected to see a reason statement that spoke to the low occupant load, or the increased cost and disproportionate use of space. Not that one sex or the other was being forced to walk a few steps further. Very surprised.

However, because I don't like to poke holes without offering solutions I am playing with a change to clarify this. Not sure if I will get it in or not, but I acknowledge how difficult it can be to write a change proposal that makes sense, using the least amount of words possible and that won't get poked full of holes by the next guy.

 

[ICE]

Quite the opposite, it was a woman that proposed it.

Ah! But did she identify as a woman?

 

[Sifu]

Ah! But did she identify as a woman?

Ahh, I needed that.

 

[classicT]

Which code and edition applies?

Without knowing, I am looking at the 2021 I-Codes. Given this... You need to consider Section 2902.2. While Table 2902.1 will identify the minimum fixture quantities given an OL, separate facilities for each sex is a requirement of 2902.2. Consider the exceptions, particularly #4.

2021 IBC [P] 2902.2 Separate Facilities​

Where plumbing fixtures are required, separate facilities shall be provided for each sex.
Exceptions:

1. Separate facilities shall not be required for dwelling units and sleeping units.
2. Separate facilities shall not be required in structures or tenant spaces with a total occupant load, including both employees and customers, of 15 or fewer.
3. Separate facilities shall not be required in mercantile occupancies in which the maximum occupant load is 100 or fewer.
4. Separate facilities shall not be required in business occupancies in which the maximum occupant load is 25 or fewer.
5. Separate facilities shall not be required to be designated by sex where single-user toilets rooms are provided in accordance with Section 2902.1.2.
6. Separate facilities shall not be required where rooms having both water closets and lavatory fixtures are designed for use by both sexes and privacy for water closets are installed in accordance with Section 405.3.4 of the International Plumbing Code. Urinals shall be located in an area visually separated from the remainder of the facility or each urinal that is provided shall be located in a stall.

 

[Sifu]

Which code and edition applies?

Without knowing, I am looking at the 2021 I-Codes. Given this... You need to consider Section 2902.2. While Table 2902.1 will identify the minimum fixture quantities given an OL, separate facilities for each sex is a requirement of 2902.2. Consider the exceptions, particularly #4.

2021 IBC [P] 2902.2 Separate Facilities​

Where plumbing fixtures are required, separate facilities shall be provided for each sex.
Exceptions:

1. Separate facilities shall not be required for dwelling units and sleeping units.
2. Separate facilities shall not be required in structures or tenant spaces with a total occupant load, including both employees and customers, of 15 or fewer.
3. Separate facilities shall not be required in mercantile occupancies in which the maximum occupant load is 100 or fewer.
4. Separate facilities shall not be required in business occupancies in which the maximum occupant load is 25 or fewer.
5. Separate facilities shall not be required to be designated by sex where single-user toilets rooms are provided in accordance with Section 2902.1.2.
6. Separate facilities shall not be required where rooms having both water closets and lavatory fixtures are designed for use by both sexes and privacy for water closets are installed in accordance with Section 405.3.4 of the International Plumbing Code. Urinals shall be located in an area visually separated from the remainder of the facility or each urinal that is provided shall be located in a stall.

Take your pick, they are all uncertain in my opinion, and not made any better by the inconsistent and ever changing use of italics. Now, since you made me look, I noticed the '21 IBC and the '21 IPC do not employ the same use of italics from one book to the other. They removed the italics from "occupancies" in the 2018 codes, which I am guessing somebody else noticed was a problem (just an editorial change?). The '24's don't have any changes from the '21's. Overall, the codes have a terrible habit of using italics incorrectly, so this is not new, and apparently not getting any better. I know there has been discussion to fix this somehow, but so far I don't see any improvement. I really only brought up the italics issue because I was hoping it would shed light on the intent via the definition, but it was no help.

 

[steveray]

To me this is an example of poor code, specifically the use of italics and conflating terms. The exceptions refer to "occupancies" as italicized in one exception, but not the other, but "occupancies" is not defined. Table specifies actual use, not occupancies, but then uses the occupancy classifications from the IBC. This question came to me from another AHJ, and I answered it the way I do it, but can't really point to a specific to justify it. I allow it, which is what I told them. The question is whether the exceptions intend to apply to use (as specified by 403.1 to use in the table) or classification (as implied by the use of the IBC terms in the table and the exceptions) but a case could be made both ways. If going with use, then the exception would not apply, if going by classification, then it would.

Run it by me or us if you want...I can see if we can get our Region VI group to support....2026 Code change hearings are in Hartford CT so I will be there and could testify in support...

 

[classicT]

Take your pick, they are all uncertain in my opinion, and not made any better by the inconsistent and ever changing use of italics. Now, since you made me look, I noticed the '21 IBC and the '21 IPC do not employ the same use of italics from one book to the other. They removed the italics from "occupancies" in the 2018 codes, which I am guessing somebody else noticed was a problem (just an editorial change?). The '24's don't have any changes from the '21's. Overall, the codes have a terrible habit of using italics incorrectly, so this is not new, and apparently not getting any better. I know there has been discussion to fix this somehow, but so far I don't see any improvement. I really only brought up the italics issue because I was hoping it would shed light on the intent via the definition, but it was no help.

Sifu, I was responding to the OP, not your later question regarding the use of italics and intent behind the use of occupancy classifications.

 

[fatboy]

Colorado Chapter is always good to work with, a powerhouse in Code Development!

 

[Sifu]

Colorado Chapter is always good to work with, a powerhouse in Code Development!

I sit in on the meetings when I can, but not sure it is the right committee for a plumbing change. I don't have near the time to devote to it as I would like.

 

[Sifu]

A closer reading of the 2024 IPC...maybe this has been clarified enough. Seems like they revised the italics, and the definition defines the intent.

[A]OCCUPANCY. The purpose for which a building or portion thereof is utilized or occupied.
(my interp) purpose=use

3.Separate toilet facilities shall not be required in mercantile occupancies in which the maximum occupant load is 100 or fewer.
(my interp) Separate facilities not required in mercantile [use] occupancies with a max. OL of 100.
4.Separate toilet facilities shall not be required in business occupancies in which the maximum occupant load is 25 or fewer.
(my interp) Separate facilities not required in business [use] occupancies with a max. OL of 25.

So if a coffee shop is classified as a B occupancy (based on 303.1.1), but is used as an assembly space, then the exception would not apply. Not sure I like it, but the code seems to clarify it. Of course anything can be interpreted in any way, and this may still leave some room for it.

(2024 IBC) 303.1.1 Small buildings and tenant spaces.​

A building or tenant space used for assembly purposes with an occupant load of less than 50 persons shall be classified as a Group B occupancy.

 

[Yikes]

Ask any woman her opinion on sharing a toilet with men. There was no women on that committee. The men must have been single.

In the old west, many women demanded separate outhouses due to the mess made by the men. In an illiterate society, the men’s outhouses would be identified with a sun symbol, the women’s with a moon (“brother sun, sister moon”).

Over the years, the salts and ammonia from poor aim caused the men’s wood framed outhouses to fall apart, while the women’s remained standing. That how we now associate the moon symbol, not the sun, with outhouses and old-times restrooms.

 

[ICE]

due to the mess made by the men

A friend worked for an arena. He said that after events, the women's bathrooms were a much bigger mess than the men's. It seems that women don't even try to hit the trash receptacles.

We recently went on a road trip. The places that had unisex restrooms were, according to her, horrible. Having used many blue rooms, I was not as disgusted as her... but they were pretty awful.

 

[fatboy]

I sit in on the meetings when I can, but not sure it is the right committee for a plumbing change. I don't have near the time to devote to it as I would like.

We have a very robust PMG contingent that could help!