# Understanding ADA restroom requirements



## Michael.L (May 15, 2018)

_Note: I wanted to break this out from my other thread because this is more about general understanding (whereas my earlier thread was about a specific layout). Hopefully, this thread will also help other business owners understand the nuances of ADA restroom requirements._

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Please help me understand the following restroom layout, taken from ADA.gov (the US DOJ's own site on ADA). It's "Plan-1B Pair" which is based on Plan-1B (Single) under the 2010 standards, but with the doors placed on the side walls so two restrooms can be built back-to-back.







Questions:

1. The image shows what appears to be a latch on the door. Yet the clear floor space approaching the push side of the door does not have the additional 12" clearance on the latch side of the door jam. Is that because this plan does not incorporate a door closer?

2. I've seen a number of ADA restroom design drawings online showing the lavatory specified as spaced away from a side wall by 18" (to the centerline of the fixture). I've included three example images below, but I've seen others. Clearly, this 18" spacing is _*not*_ the case for virtually all the 2010 Standards plans published by ADA.gov. You can see just by eye that the lavatory is closer than 18" to the side wall with the entry door in Plan-1B Pair, shown above. Are all these restroom designs showing 18" of lavatory spacing from a side wall based on a misinterpretation of the code (perhaps confused with the required 16"-18" lateral spacing of the water closet)? Or are these designs just going beyond what the code requires? Or is there an 18" spacing requirement for lavatories of which I am unaware?


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## cda (May 15, 2018)

Not into toilets

Is the one showing 18, just another way of showing the entire 96 as in the bottom picture


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## TheCommish (May 15, 2018)

having both a closure and a latch requires  the clearance,  having one of the 2 does not is my understanding


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## Michael.L (May 15, 2018)

TheCommish said:


> having both a closure and a latch requires  the clearance,  having one of the 2 does not is my understanding


That's been my interpretation as well: a logical "AND" means both are required both for the condition to be met. But that begs the question: when would a single-occupancy commercial restroom have a closer but no latch?


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## Michael.L (May 15, 2018)

cda said:


> Is the one showing 18, just another way of showing the entire 96 as in the bottom picture


I'm not sure what you mean by "the entire 96." Are you referring to the turning circle diameter in the bottom image?


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## steveray (May 15, 2018)

Michael.L said:


> That's been my interpretation as well: a logical "AND" means both are required both for the condition to be met. But that begs the question: when would a single-occupancy commercial restroom have a closer but no latch?



Typically not....

1109.2.1.7 Privacy. Doors to family or assisted-use toilet and
bathing rooms shall be securable from within the room.


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## cda (May 15, 2018)

Michael.L said:


> I'm not sure what you mean by "the entire 96." Are you referring to the turning circle diameter in the bottom image?


 Yes

60+18+18=   96


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## Rick18071 (May 15, 2018)

you could have a door without a latch and a bolt lock for privacy.


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## ADAguy (May 15, 2018)

Typically lavs are approached preferably from the front, that being the case in "new" construction 18" min. clr. to finish face of side wall is required.
Maybe you should consider attending the annual National ADA Symposium put on by the University of Missouri, many of the Access Boards staff are there to answer questions such as yours as is ADA Technical Assistance (800) 949 4232.


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## my250r11 (May 15, 2018)

18" is the CENTER of the 36" clear space.


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## georgia plans exam (May 15, 2018)

I know of no code that has an 18" requirement from a side wall to the center line of a lavatory. If I am mistaken, please someone educate me. We use the 2010 ADASAD here.

Thanks, GPE.


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## georgia plans exam (May 15, 2018)

36" clear space is only required if the forward approach were recessed more than 24". Section 305.7.1 2010 ADASAD. Otherwise, the clear floor space is only required to be 30".   GPE.


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## Michael.L (May 15, 2018)

Rick18071 said:


> you could have a door without a latch and a bolt lock for privacy.


Really? I thought that would also be considered a latch. So is a deadbolt lock (twist handle on the inside, keyed cylinder on the outside) not considered a latch? That would be a great solution for reducing clear floor space.

Do you have the code section I could reference on what constitutes a "latch"?


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## Michael.L (May 15, 2018)

ADAguy said:


> Typically lavs are approached preferably from the front, that being the case in "new" construction 18" min. clr. to finish face of side wall is required.


Can you point me to this requirement in the code? All I've found is that the lavatory must have 30"W x 48"D clear space in front of it. I've read that 15" from CL of lavatory to face of side wall is required (but 18" is recommended).



ADAguy said:


> Maybe you should consider attending the annual National ADA Symposium put on by the University of Missouri, many of the Access Boards staff are there to answer questions such as yours as is ADA Technical Assistance (800) 949 4232.


I'm not aiming to become an architect, contractor, or inspector. I'm just trying to learn as much as I can of what I need in order to correctly assess the preliminary layout of our food service establishment _before_ hiring an architect for drafting of our plans for permitting. What I'm doing is research in advance so I can determine if the space we're considering leasing will work for our business _before_ I commit to hiring the architect. I don't want to waste costly hours of an architect's billable time only to learn afterward that this space won't work for our business needs.

The additional benefit of learning the code is that it will help me understand what the architect does and to act as a second set of eyes for reviewing his/her work as the plans are being developed and before submitting for permitting. It also helps ensure that our business _remains_ compliant in the future. For example, how many business owners place a waste bin in the clear floor space required around the water closet? From the photos of ADA restrooms I've seen online, I'd say the vast majority of businesses commit this violation. It's one thing to design and build an ADA-compliant restroom, it's quite another to keep it compliant in day-to-day business operations.


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## Sleepy (May 15, 2018)

GPE, I'm with you, I only see the requirement for 30" wide, unless in an alcove (in my case from ABA 2015 paras. 606.2 and 306).


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## Sleepy (May 15, 2018)

Michael.L said:


> For example, how many business owners place a waste bin in the clear floor space required around the water closet?



I may be wrong, but I've always thought this was ok, as long as the waste bin is moveable.  There also is usually one in the clear area near the door in multi-user toilet rooms.


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## ADAguy (May 16, 2018)

ADA requires "maintenance" of access features. Though waste receptacles are not "fixed" elements they must be kept clear of maneuvering spaces.


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## ADAguy (May 16, 2018)

Sleepy said:


> GPE, I'm with you, I only see the requirement for 30" wide, unless in an alcove (in my case from ABA 2015 paras. 606.2 and 306).





See, he said.


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## georgia plans exam (May 16, 2018)

I see a diagram showing 18". Where is the code section? Is it a CBC requirement?


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## ADAguy (May 16, 2018)

Yes Georgia, CBC 11B 606.6


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## georgia plans exam (May 16, 2018)

Ok, thanks ADAguy.


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## Michael.L (May 16, 2018)

ADAguy said:


> Yes Georgia, CBC 11B 606.6


I didn't specify in this thread, but I'm located in Colorado, not California. So for federal ADA, there is no 18" to CL requirement for lavatories?

I'm still trying to research if there are any overriding Colorado BC requirements.


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## mp25 (May 16, 2018)

From my understanding of the ADA, the clearspace for the sink does not have to be centered. If you look at section 602.2 that discusses drinking fountains or 611.2 that discusses washing/drying machines, it specifically says in that section that clear space for a drinking fountain/washer/dryer must be centered on the unit/appliance. The sink section of the code does not specifically state that - which leads to my interpretation that it does not have to be centered (although it certainly would by nice).


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## Builder Bob (May 17, 2018)

I do have a problem with the original post, it appears the lavatories are encroaching upon the required 18" or 12" inches = hell if I know at this time -- sorry drinking to much beer ------ required floor space for the door approach - see other post in your original post and you will see what I mean.... The great State of South Carolina Adopted the 2017 ICC ANSI A117.1 for accessibility, apparently, I cannot have a hand dryer located on the wall because it encroaches upon the required door approach clearances - therefore We have specified that doors are to be locate 4" from adjacent walls to ensure the hand dryers do not encroach upon the required door approach clearances in the accessibility code adopted by the great state of South Carolina --- BTW , research which state lead the nation in adopting the International Building Codes which have increased construction cost in our region by upwards of 75 to 100 %  prior to adoption of this wonderful code..... OK rant over, Peace, goodwill, and may mankind prosper! Spock Out


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## Michael.L (May 17, 2018)

Builder Bob said:


> I do have a problem with the original post, it appears the lavatories are encroaching upon the required 18" or 12" inches = hell if I know at this time -- sorry drinking to much beer ------ required floor space for the door approach. Spock Out


Spock... err... Bob, as I've read more about the ins-and-outs of accessibility code, the more I'm convinced that Plan-1B Pair (as illustrated in my original post) is designed with no closer. Or perhaps what looks like a "latch" is not actually a "latch" but something like a deadbolt or sliding privacy lock that's not spring-loaded (see my other post about deadbolts vs latches).

If it's the latter (deadbolt type privacy lock), then Plan-1B Pair makes sense and is a good design. If the former (no closer), then Plan-1B Pair is misleading because a closer on restroom doors is at least recommended, and in some jurisdictions, it's required.


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## Michael.L (May 17, 2018)

I just found an interesting tidbit that seems to back up my position that a deadbolt, by itself, is not a latch.


> Because this is a fire door, it must close and latch to deter the spread of smoke and flames. NFPA 80 addresses products which do not latch each time the door closes, but requires that _“in a fire emergency, the door becomes positively latched by means of an automatic fail-safe device that is activated by an automatic fire detector.”_



Note the focus on the requirement for a "latch" to actually latch (secure) the door _automatically _when the door is in the closed position_._ A manually-operated deadbolt will never automatically latch a door. To me, this means that a deadbolt is not considered a "latch" for the purposes of building, fire, and accessibility codes; instead, a deadbolt falls under the category of "a product which does not latch each time the door closes."


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## cda (May 17, 2018)

Michael.L said:


> I just found an interesting tidbit that seems to back up my position that a deadbolt, by itself, is not a latch.
> 
> 
> Note the focus on the requirement for a "latch" to actually latch (secure) the door _automatically _when the door is in the closed position_._ A manually-operated deadbolt will never automatically latch a door. To me, this means that a deadbolt is not considered a "latch" for the purposes of building, fire, and accessibility codes; instead, a deadbolt falls under the category of "a product which does not latch each time the door closes."




Send your question to the hardware guru, and you will get fantastic answers!!!!!


http://idighardware.com/2015/07/restroom-locks-and-latches/


http://idighardware.com/about-2/


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## Michael.L (May 17, 2018)

cda said:


> Send your question to the hardware guru, and you will get fantastic answers!!!!!


Yep. I'm going to start by dropping a note to Lori in her "Hardware" forum here, asking her to check out this thread.


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## Michael.L (May 17, 2018)

Oops, I just realized that the last two posts should have been in my "deadbolt" thread.


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## cda (May 17, 2018)

Michael.L said:


> Yep. I'm going to start by dropping a note to Lori in her "Hardware" forum here, asking her to check out this thread.




Email is the fastest


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## ADAguy (May 17, 2018)

"Dead" as it implies is just that, it stays in place at all times where you place it, requiring an effort to move it at any time. The same may not be true of various types of latches which may or may not contain springs, slide bars or rotate to operate elements.
The point being per ADA compliance that the door should be openable with little effort (minimum resistance by hinges) other that to push against it (in a perpendicular manner to the door face) without multiple actions being required of the pusher.


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## Michael.L (May 17, 2018)

ADAguy said:


> The point being per ADA compliance that the door should be openable with little effort (minimum resistance by hinges) other that to push against it (in a perpendicular manner to the door face) without multiple actions being required of the pusher.


But the intent is not to eliminate multiple actions; it's to eliminate multiple *simultaneous* actions.

It takes two independent actions to open a door with a latch, but no closer: (1) HOLD open the latch against the resistance of the latching mechanism; and (2) Swing open the door. This is acceptable because, while effort is required to hold open the latch, there's virtually no effort required to swing open a door that has no closer.

It takes two independent actions to open a door with a deadbolt and a closer: (1) Retract the bolt; and (2) Push open the door against the resistance of the closer. This should also be acceptable because, there is no effort expended on the deadbolt after it is retracted, only effort to overcome the resistance of the closer.

The requirement for additional clear floor space when there is both a latch _*and*_ a closer, is because the user must overcome the resistance of the latching mechanism while *simultaneously* overcoming the resistance of the closer. The additional effort to perform both tasks simultaneously is the challenge that requires additional working space for a disabled user.


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## Michael.L (May 17, 2018)

cda said:


> Email is the fastest


Lori replied in this forum 35 minutes before you posted this!


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