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Unisex Restroom inside Office TI

Ryan M

Registered User
Joined
Nov 2, 2023
Messages
3
Location
Las vegas
I have an office TI that the owner wants an unisex restroom inside their space. The base building provides restrooms for the entire floor already in the communal space. So this restroom is not required by any plumbing calculation. Are we required to make this ADA compliant with grab bars and accessible sink? The owner will only have 5 people working in the space and will rarely have guests.

Thanks,
 

2021 IBC - 1110.2 Toilet and Bathing Facilities

Each toilet room and bathing room shall be accessible. Where a floor level is not required to be connected by an accessible route, the only toilet rooms or bathing rooms provided within the facility shall not be located on the inaccessible floor. Except as provided for in Sections 1110.2.4 and 1110.2.5, at least one of each type of fixture, element, control or dispenser in each accessible toilet room and bathing room shall be accessible.
Exceptions:

  1. Toilet rooms or bathing rooms accessed only through a private office, not for common or public use and intended for use by a single occupant, shall be permitted to comply with the specific exceptions in ICC A117.1.
  2. This section is not applicable to toilet and bathing rooms that serve dwelling units or sleeping units that are not required to be accessible by Section 1108.
  3. Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50 percent but not less than one room for each use at each cluster shall be accessible.
  4. Where no more than one urinal is provided in a toilet room or bathing room, the urinal is not required to be accessible.
  5. Toilet rooms or bathing rooms that are part of critical care or intensive care patient sleeping rooms serving Accessible units are not required to be accessible.
  6. Toilet rooms or bathing rooms designed for bariatrics patients are not required to comply with the toilet room and bathing room requirement in ICC A117.1. The sleeping units served by bariatrics toilet or bathing rooms shall not count toward the required number of Accessible sleeping units.
  7. Where permitted in Section 1108, in toilet rooms or bathrooms serving Accessible units, water closets designed for assisted toileting shall comply with Section 1110.2.2.
  8. Where permitted in Section 1108, in bathrooms serving Accessible units, showers designed for assisted bathing shall comply with Section 1110.2.3.
  9. Where toilet facilities are primarily for children's use, required accessible water closets, toilet compartments and lavatories shall be permitted to comply with children's provision of ICC A117.1.
 
Yes, you need all single user toilet rooms to be accessible (with some exceptions, but if there's only one toilet room, none of those exceptions apply).
 
To clarify my some confusion:

Toilet rooms or bathing rooms accessed only through a private office, not for common or public use and intended for use by a single occupant, shall be permitted to comply with the specific exceptions in ICC A117.1.

When they say "Private Office" would this mean a single person office or could it apply to the overall office space?
It would not be a used by the "Public" but not sure what they consider "Common" if 5 people use it is it considered "Common"?
and when they say "Single Occupant" do they mean only 1 person can ever use it or only 1 person at a time?
 
When they say "Private Office" would this mean a single person office or could it apply to the overall office space?
It would not be a used by the "Public" but not sure what they consider "Common" if 5 people use it is it considered "Common"?
and when they say "Single Occupant" do they mean only 1 person can ever use it or only 1 person at a time?
Yes, it means a single person office.
Note that the private office exception only grants some minor exceptions such as the grab bars being installed (blocking still has to be there), roll-under sink (removable cabinet required), etc. Basically, the bathroom has to be readily convertible to being accessible.
 
I have an office TI that the owner wants an unisex restroom inside their space. The base building provides restrooms for the entire floor already in the communal space. So this restroom is not required by any plumbing calculation. Are we required to make this ADA compliant with grab bars and accessible sink? The owner will only have 5 people working in the space and will rarely have guests.

Thanks,
And Welcome to THE Forum!.....
 
To clarify my some confusion:

Toilet rooms or bathing rooms accessed only through a private office, not for common or public use and intended for use by a single occupant, shall be permitted to comply with the specific exceptions in ICC A117.1.

When they say "Private Office" would this mean a single person office or could it apply to the overall office space?

Yes. This would apply if, for example, the CEO has a private toilet room in his private office, reserved for his use only.

It would not be a used by the "Public" but not sure what they consider "Common" if 5 people use it is it considered "Common"?

Yes.

and when they say "Single Occupant" do they mean only 1 person can ever use it or only 1 person at a time?

A single-occupant toilet room is what we refer to in the vernacular as a "one holer." It's a toilet room containing a single water closet.
 
From the IBC 2021 Commentary for 1110.2, exceptions:

Exception 1 addresses a condition in which a toilet
room or bathing room is permitted to be adaptable
rather than fully accessible. The intent is that if a toilet
room is part of an individual office and serves only the
occupant of that office, the adaptable toilet room can
be readily modified to be fully accessible based on that
individual’s needs. Preplanning during construction
and design will facilitate future alterations. The ICC
A117.1 indicates exactly what those adaptable features
can be (e.g., reversible door swing; water closet
seat height; blocking for grab bars; removable cabi-
nets under the lavatory). This is not intended to be a
general exception to allow a very small bathroom that
would require walls or fixtures relocated to provide
accessibility at a later date. The bathrooms must be
sized to be accessible.
[emphasis added]
 
Why do you say that? I interpret “single occupant” to mean one person in the restroom at a time, not a family-style room or a room with stalls.

The "single occupant" in the relevant code section refers to the toilet room, not to the office. That said, if a single office is occupied by more than one person, it is not a private office, it is a "common" office. Note that the commentary refers to "the occupant [singular] of that office."
 
Why do you say that? I interpret “single occupant” to mean one person in the restroom at a time, not a family-style room or a room with stalls.
Because that is what it says (about the office anyway)... keep in mind that it's not about the toilet room, but is about the office. 1110.2 Exception #1.

accessed only through a private office, not for common or public use and intended for use by a single occupant
 
Yes, it means a single person office.
Note that the private office exception only grants some minor exceptions such as the grab bars being installed (blocking still has to be there), roll-under sink (removable cabinet required), etc. Basically, the bathroom has to be readily convertible to being accessible.
So many times I have had designers think they were exempt from all accessibility. In my experience, this exemption is rare.
 
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