# Wall cabinet above ADA toilet?



## PatrickGSR94 (Sep 21, 2020)

I have a client who wants to install a wall cabinet for toiletry storage in 2-user restrooms, each one having an ADA accessible stall, and a regular stall (women's) and urinal (men's).  I've seen similar cabinets in many fast-food and other restaurants, like Starbucks, etc.  However I'm not sure if that would be considered a Protruding Object (which is usually "along the accessible route") or if it could be considered a shelf, etc.  With a person sitting on a toilet, they're really not ever closer than 12 inches to the back wall, especially when in the seated position, or in the standing position.

What say you?  I have Google searched to no end and cannot find anything definitive on the subject.


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## PatrickGSR94 (Sep 21, 2020)

If it's not allowed above the ADA toilet, then perhaps a cabinet could go above the non-accessible toilet and urinal, correct?


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## ADAguy (Sep 21, 2020)

Depends on whether it is a tank or flushometer type toilet. Avoid head knockers when seated.
Is it for employees only? Consider reach ranges for short people.


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## PatrickGSR94 (Sep 21, 2020)

Employee toilet rooms, tank type toilets.


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## classicT (Sep 21, 2020)

Based upon A117.1 604.3.3, shelves are allowed within the clear floor space for a toilet.



The code section referred to by the OP would be 1003.3, which does not specify accessible routes, but circulation paths. The rear wall of a toilet room would not be an accessible route nor a circulation pathway.

*1003.3 Protruding Objects*
Protruding objects on circulation paths shall comply with the requirements of Sections 1003.3.1 through 1003.3.4. 

Therefore, as ADAguy said, verify the cabinet does not protrude so far as to give someone a headache when they stand-up from the toilet.


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## PatrickGSR94 (Sep 21, 2020)

Based on the cut sheets for the toilets we're using, a person would have to be straddling the bowl in order for their head to contact a cabinet above it.


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## steveray (Sep 21, 2020)

I know we had a lengthy discussion on this previously and a little unfortunate that we don't have a "god clause" in this case(IBC)like the IRC in 2705

4. Plumbing fixtures shall be usable.


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## ADAguy (Sep 22, 2020)

PatrickGSR94 said:


> Based on the cut sheets for the toilets we're using, a person would have to be straddling the bowl in order for their head to contact a cabinet above it.



Picture a "tall person" sitting on the stool and leans back.


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## north star (Sep 24, 2020)

*# ~ #*



> *" Based on the cut sheets for the toilets we're using, a person would have to be straddling the bowl in order for their head to contact a cabinet above it. "*


Stranger things have happened...…..Seems like an odd place to store toiletry items......Is there any other place to store [ typical ] custodial items ?
*# ~ #*


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## Yikes (Sep 24, 2020)

As shelving, it is allowed per Ty J's comment on 604.3.3.
However, keep in mind that that to the extent the area around the toilet is also a "circulation path" for persons utilizing the toilet, the cabinet can't create a hazard for a blind person.  There is a 4" limit for protruding objects (ADAS 307.2).  The shape of toilet itself can function as a warning device below 27" high.  If it is a tankless toilet, the cabinet above may pose a hazard that protrudes more than 4" beyond the toilet footprint.


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## Camilo Vasquez (Oct 1, 2020)

PatrickGSR94 said:


> I have a client who wants to install a wall cabinet for toiletry storage in 2-user restrooms, each one having an ADA accessible stall, and a regular stall (women's) and urinal (men's).  I've seen similar cabinets in many fast-food and other restaurants, like Starbucks, etc.  However I'm not sure if that would be considered a Protruding Object (which is usually "along the accessible route") or if it could be considered a shelf, etc.  With a person sitting on a toilet, they're really not ever closer than 12 inches to the back wall, especially when in the seated position, or in the standing position.
> 
> What say you?  I have Google searched to no end and cannot find anything definitive on the subject.



It appears that this shelf is mounted above the toilet and on the rear wall of the toilet. If this is the case, then it's not so much about protrusion but about encroachment into the toilet (water closet) clearance. There seems to be a grey area in Section 604.3.3 in the 2010 ADA Standards which states "associated grab bars,...shelves.." are permitted to overlap the water closet. 

Locating shelving over the water closet might seem trivial; but, it can have a big effect on a person with a disability who is trying to utilize the fixture. The intent of Section 604.3, including 604.3.2, is that the clearance be “clear” to allow for maneuverability and transfer to the water closet from different angles. A shelf located over the water closet, even if it is located in the corner can impact maneuverability and transfer. There is a lot of guidance from the US Access Board regarding water closet clearance. 

The key caveat in section 604.3.2 is the word “associated” which modifies the words that follow in the exception. In other words, the exception should be read as follows: “The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, associated paper dispensers, associated sanitary napkin receptacles, associated coat hooks, associated shelves…”. The intent of the exception is to acknowledge that certain elements are necessary for the use of the water closet and necessary to overlap the required water closet clearance. An associated shelf would be a purse shelf, for instance. Storage shelves, however, are not associated with the use of the water closet, and thus not permitted to overlap.


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## Yikes (Oct 1, 2020)

Camilo Vasquez said:


> The key caveat in section 604.3.2 is the word “associated” which modifies the words that follow in the exception. In other words, the exception should be read as follows: “The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, associated paper dispensers, associated sanitary napkin receptacles, associated coat hooks, associated shelves…”. The intent of the exception is to acknowledge that certain elements are necessary for the use of the water closet and necessary to overlap the required water closet clearance. An associated shelf would be a purse shelf, for instance. Storage shelves, however, are not associated with the use of the water closet, and thus not permitted to overlap.


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## Yikes (Oct 1, 2020)

Camilo Vasquez said:


> The key caveat in section 604.3.2 is the word “associated” which modifies the words that follow in the exception. In other words, the exception should be read as follows: “The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, associated paper dispensers, associated sanitary napkin receptacles, associated coat hooks, associated shelves…”. The intent of the exception is to acknowledge that certain elements are necessary for the use of the water closet and necessary to overlap the required water closet clearance. An associated shelf would be a purse shelf, for instance. Storage shelves, however, are not associated with the use of the water closet, and thus not permitted to overlap.



Here's the actual wording:



I have 2 comments:
(1) You have interpreted that the word "associated" within the structure of the sentence to apply to the noun that follows it, but you stopped at "shelves".  If you were being consistent, you would apply it to "accessible routes, clear floor space and clearances required at other fixtures".  But no one says that clearance at a water closet can't overlap clearance at a sink.  I think this points out the subjective nature of interpreting the word "associated".  The adopted code language does not provide that clarity.
(2) For the sake of discussion, let's stipulate your interpretation that the shelf must be associated with the toilet.  Who is to say that a shelf holding a purse is more "associated" with a water closet than a shelf storing spare toilet paper, or even a plunger?  In fact, purses, coats and sanitary napkins are all things that you try to avoid putting into a water closet.


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## ADAguy (Oct 1, 2020)

That is why the backs of stall doors have hooks, duh? It is not a gas station RR, is it?


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## Phil B (Dec 14, 2021)

Could you locate a water heater in the corner of an accessible toilet room as long as all clearances are met?


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## steveray (Dec 14, 2021)

Phil B said:


> Could you locate a water heater in the corner of an accessible toilet room as long as all clearances are met?


yep


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## ICE (Dec 14, 2021)

Phil B said:


> Could you locate a water heater in the corner of an accessible toilet room as long as all clearances are met?


Direct vent or electric are allowed….other fuel-burning are not.


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## Phil B (Dec 15, 2021)

ICE said:


> Direct vent or electric are allowed….other fuel-burning are not.


Thank you. Could you please guide me to the correct code section?


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## ICE (Dec 15, 2021)

Phil B said:


> Thank you. Could you please guide me to the correct code section?


504.1 in the 2019 California Plumbing Code which is based on the 2018 Uniform Plumbing Code.  We did not adopt the plumbing code sections that are found in the International Residential Code.


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## Inspector Gift (Dec 15, 2021)

classicT said:


> Based upon A117.1 604.3.3, shelves are allowed within the clear floor space for a toilet.
> View attachment 6981
> 
> 
> ...



A QUESTION NOT YET ASKED:   "*IS THE WALL CABINET REQUIRED TO BE ACCESSIBLE?*"

I would answer "NO" to PatrickGSR94's question.  
An accessible wall cabinet may not be located over the toilet.


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## Rick18071 (Dec 16, 2021)

Shelf's allowed in water closet clear area always bugged me after I saw a shelf unit sitting on the floor next to the toilet one time. I could not require it to be moved because of this code section.


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## ADAguy (Jan 9, 2022)

Open or closed storage? If open what happens in a quake? if closed with a lock accessible to employees only? What of reach range compliance?
Code is still exceeded by ADA minimums. even if you claim AHJs don't enforce ADA, architects and clients must comply.


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## Rick18071 (Jan 10, 2022)

ADAguy said:


> Open or closed storage? If open what happens in a quake? if closed with a lock accessible to employees only? What of reach range compliance?
> Code is still exceeded by ADA minimums. even if you claim AHJs don't enforce ADA, architects and clients must comply.


I would not allow a cabinet over the toilet. The code is clear that shelves are allowed but not cabinets. This does not make sense to be but other sections also do not make sense to me.


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## Jean Tessmer-HI (Jan 17, 2022)

PatrickGSR94 said:


> I have a client who wants to install a wall cabinet for toiletry storage in 2-user restrooms, each one having an ADA accessible stall, and a regular stall (women's) and urinal (men's).  I've seen similar cabinets in many fast-food and other restaurants, like Starbucks, etc.  However I'm not sure if that would be considered a Protruding Object (which is usually "along the accessible route") or if it could be considered a shelf, etc.  With a person sitting on a toilet, they're really not ever closer than 12 inches to the back wall, especially when in the seated position, or in the standing position.
> 
> What say you?  I have Google searched to no end and cannot find anything definitive on the subject.


Since the use is not for the public but for (it sounds like?) janitorial storage (?), it is locked for that purpose and only if the finished bottom of the cabinet is more than 30".  Figure 609.4 position of grab bars-(a) projecting objects shows projection at 12" above the the grab bar, but they don't tell you how far out the projection can go.  Looks like 3".  You may want to call the ADA technical assistance line to verify what they say that projection is.


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## Jean Tessmer-HI (Jan 18, 2022)

1. If the wall cabinet is only for the use of qualified maintenance folks and not for public access.
2. if the cabinet is secured so it cannot be opened by anyone else but the qualified maintenance person.
3. if you can locate it so it provides vertical clearance above the back wall toilet grab bar.
4. if you can make sure it is not a protruding object (the toilet will act as a detectable warning).
5. if you can call the DOJ ADA technical assistance line and ask them or some one at TA the US Access Board (USAB is better at looking at speaking to caviates to the code and they wrote it for DOJ) and they say its ok.


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## ADAguy (Jan 19, 2022)

Consider that the head of a tall seated person may be higher than 48" ( btwn 27 & 80") and within > 4" of the rear wall if on a tankless WC even if the 12" projecting storage is locked.


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## Paul Sweet (Jan 20, 2022)

Post #4 said tank toilets.  I think it would meet the intent of ADA if it didn't extend out farther than the tank and was the required distance above the grab bar.


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