Toilet rooms: fixture and transfer clearances

Chapter 6: Plumbing Elements and Facilities Toilet Rooms Compliance in an alteration is not required where it is “technically infeasible.” The term is defined as “something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.” For example, combining two toilet compartments to create an accessible compartment may be technically infeasible where it would reduce the fixture count below the number required by the applicable plumbing code. When it is technically infeasible to make existing men’s and women’s rooms comply, an accessible unisex toilet room can be provided instead if it is in the same area and on the same floor as the existing toilet rooms (§213.2, Ex. 1). Where technical infeasibility is encountered, compliance is still required to the maximum extent feasible. Alterations and Additions to Primary Function Areas [§202.4] When an area containing a primary function (a major activity intended for a facility) is altered or added to a facility, an “accessible path of travel” is required. The accessible path of travel, which must extend from site arrival points to the primary function area, includes provided restrooms (at least one for each sex or, if only unisex restrooms are provided, at least one unisex restroom), telephones, and drinking fountains, where provided, that serve the primary function area. The accessible path of travel is required to the extent that it does not cost more than 20% of the total cost of the work to the primary function area. Compliance is required up to the point this cost cap is reached, even where it does not result in a fully accessible path of travel. See the Alterations and Additions Guide. Alterations to Qualified Historic Facilities [§202.5, §213] The Standards provide certain exceptions for qualified historic facilities where compliance in an alteration would threaten or destroy the historic integrity or significance of a facility as determined by the appropriate State Historic Preservation Official or Advisory Council on Historic Preservation. One of these exceptions allows access to be provided to a unisex toilet room or to one men’s and one women’s room regardless of the number of toilet rooms altered or added (§213.2, Ex. 2). This guide notes some provisions in the International Building Code (IBC) and the ICC A117.1 Standards for Accessible and Usable Buildings and Facilities that are not found in the ADA Standards. For example, the A117.1 standard, which provides technical provisions and is referenced by the IBC, requires a vertical grab bar at water closets. Not all differences between the ADA Standards and editions of the IBC and A117.1 standard are noted in this guide. 4