# What percentage of restrooms need to be accessible?



## Bigwood (Dec 28, 2020)

We are putting in an A-5 business (axe throwing) into an existing building with no restrooms. I see the chart shows 1 male bathroom per 75 occupants and 1 female bathroom per 40 occupants. Occupancy load will be around 200. What percentage of these restrooms need to be accessible? 2015 IBC. Is it at least 50% if we build them in a cluster? How many if we don't build them in a cluster?


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## RLGA (Dec 28, 2020)

All restrooms are required to be accessible. Refer to the first sentence in IBC Section 1109.2. However, there are some exceptions listed for this section. For example, in Exception 3, only 50% are required to be accessible if provided as a cluster of single-user toilet rooms.


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## Bigwood (Dec 29, 2020)

RLGA said:


> All restrooms are required to be accessible. Refer to the first sentence in IBC Section 1109.2. However, there are some exceptions listed for this section. For example, in Exception 3, only 50% are required to be accessible if provided as a cluster of single-user toilet rooms.


Thank-you!!!


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## mark handler (Dec 29, 2020)

You said you are putting it "in"  an A-5, A-5 is outdoor sporting? 
 You Split the 200  into 100 male 100 female.
As Ron Stated above, Or:
If the rooms are multi-occupant, you can put in one male accessible toilet, with one accessible urinal. And One female accessible Toilet with one non-accessible.
Or:
Split up the locations and build four accessible toilets


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## Bigwood (Dec 29, 2020)

Our engineer told me it would fall under A-5. The only other classification I see appropriate would be A-3. What are you thinking? As far as the women's - if it is 1 per 40, don't we need 3 W/C's?


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## RLGA (Dec 29, 2020)

mark handler said:


> You said you are putting it "in"  an A-5, A-5 is outdoor sporting?
> You Split the 200  into 100 male 100 female.
> As Ron Stated above, Or:
> If the rooms are multi-occupant, you can put in one male accessible toilet, with one accessible urinal. And One female accessible Toilet with one non-accessible.
> ...


Correct. I didn't mean that all water closets, urinals, and lavatories are required to be accessible--just the restrooms. So if you provide separate men's and women's restrooms with water closet compartments, only 5% (but not less than one) of each fixture is required to be accessible.


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## Bigwood (Dec 29, 2020)

RLGA said:


> Correct. I didn't mean that all water closets, urinals, and lavatories are required to be accessible--just the restrooms. So if you provide separate men's and women's restrooms with water closet compartments, only 5% (but not less than one) of each fixture is required to be accessible.


Ok, this makes much more sense now. Thanks!


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## ADAguy (Dec 29, 2020)

Be wary of women throwing axes.


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## Bigwood (Dec 29, 2020)

ADAguy said:


> Be wary of women throwing axes.


Or just run really, really fast in a zigzag pattern and I'm sure you'll make it out alive!


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## Bigwood (Jan 4, 2021)

mark handler said:


> You said you are putting it "in"  an A-5, A-5 is outdoor sporting?
> You Split the 200  into 100 male 100 female.
> As Ron Stated above, Or:
> If the rooms are multi-occupant, you can put in one male accessible toilet, with one accessible urinal. And One female accessible Toilet with one non-accessible.
> ...


Are urinals interchangeable with toilets for men? We are required to have two men's toilets. We were planning to have one accessible toilet, one accessible urinal and one regular urinal. Is this acceptable?


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## RLGA (Jan 4, 2021)

You're required to have three water closets (100/40 = 2.5, must round up, so 3).

You can substitute up to 67% of the required water closets with urinals for assembly occupancies. Therefore, 67% of 3 is 2, so yes, you can have 2 urinals.


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## instantmessenger (Jan 16, 2021)

Just wanted to point out that the required amount of accessible bathrooms is not a minimum of 50% as stated above. The required amount is to have “not more than 50%”. There is a big difference.


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## RLGA (Jan 16, 2021)

instantmessenger said:


> Just wanted to point out that the required amount of accessible bathrooms is not a minimum of 50% as stated above. The required amount is to have “not more than 50%”. There is a big difference.


Huh? Where are you finding that? Exception 3 to Section 1109.2 states “*at least 50 percent* but not less than one room for each use at each cluster shall be accessible.”


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## mark handler (Jan 16, 2021)

RLGA said:


> Huh? Where are you finding that? Exception 3 to Section 1109.2 states “*at least 50 percent* but not less than one room for each use at each cluster shall be accessible.”


In CA at least five percent, not less than one....


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## RLGA (Jan 16, 2021)

mark handler said:


> In CA at least five percent, not less than one....


It’s the same in the IBC for fixtures within a multiuser restroom. The 50% requirement applies to single-user toilet rooms clustered together in one location.


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## instantmessenger (Jan 16, 2021)

RLGA said:


> Huh? Where are you finding that? Exception 3 to Section 1109.2 states “*at least 50 percent* but not less than one room for each use at each cluster shall be accessible.”


Interesting, ADA 2010 Standards 213.2 Toilet Rooms and Bathing Rooms, Exception 4:
Where multiple single user toilet rooms are clustered at a single location, *no more than 50 percent* of the single user toilet rooms for each use at each cluster shall be required to comply with 603.


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## RLGA (Jan 16, 2021)

I guess the ADA Standards could be interpreted to allow less than 50%, but I don’t think that was the intent. However, if the project is subject to the IBC, then the clarity of the IBC will take precedence.


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## instantmessenger (Jan 16, 2021)

RLGA said:


> I guess the ADA Standards could be interpreted to allow less than 50%, but I don’t think that was the intent. However, if the project is subject to the IBC, then the clarity of the IBC will take precedence.


Huh? So you "guess" it could be interpreted that way, but you don't "think" that was the intent? You "feel" IBC has more clarity? These are all your personal interpretations.

ADA Standards were written that way for a very specific reason. Whether you agree with it or not, that is exactly the intent.


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## RLGA (Jan 16, 2021)

instantmessenger said:


> Huh? So you "guess" it could be interpreted that way, but you don't "think" that was the intent? You "feel" IBC has more clarity? These are all your personal interpretations.
> 
> ADA Standards were written that way for a very specific reason. Whether you agree with it or not, that is exactly the intent.


Anything in the ADA Standards and the IBC (or any code or law for that matter) is subject to interpretation. Writers of codes, laws, and standards always have an intent in mind when writing them; however, the implementation does not always turn out exactly the way they intended.

If the requirement you quoted from the ADA Standards is to be interpreted to mean that anything under 50% is okay, then why would anyone install accessible restrooms when they are clustered? Do you really think it was the intent of the Access Board and DOJ to permit the reduction of restroom accessibility in public accommodations?

My interpretation of the ADA requirement is that 50% "shall be required," but "no more than 50 percent." Again, it is not the clearest way to say "at least 50 percent" as stated in the IBC. 

If both the ADA Standards and IBC are applicable to a building, then the IBC very succinctly states that 50% must be accessible, regardless of how someone would interpret the ADA Standards.


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## instantmessenger (Jan 16, 2021)

It’s interesting and the difference between the two is very important. It adds up to real dollars. Your interpretation adds a significant burden, the difference could be a project being scaled down or not happening, which in turn would be less accessible as a result. So to answer your question, depending on the occupancy totals single user cluster bathrooms can be required to have 3 total. In this scenario your interpretation requires 66.6% to be accessible (not less than 50%). In the same exact same scenario my reading of it requires 33.3% to be accessible (not more than 50%). Given that a much lower percentage of the population would require this accommodation, you are adding a lot of unjustifiable red tape. The fact that other parts of accessible design only requires 5 or 10 percent accessibility, a requirement of 66.6% is extreme fringe. I know you are trying to be cautious but requiring fringe as a baseline is not in the spirit of the codes.


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## mark handler (Jan 18, 2021)

instantmessenger said:


> It’s interesting and the difference between the two is very important. It adds up to real dollars. Your interpretation adds a significant burden, the difference could be a project being scaled down or not happening, which in turn would be less accessible as a result. So to answer your question, depending on the occupancy totals single user cluster bathrooms can be required to have 3 total. In this scenario your interpretation requires 66.6% to be accessible (not less than 50%). In the same exact same scenario my reading of it requires 33.3% to be accessible (not more than 50%). Given that a much lower percentage of the population would require this accommodation, you are adding a lot of unjustifiable red tape. The fact that other parts of accessible design only requires 5 or 10 percent accessibility, a requirement of 66.6% is extreme fringe. I know you are trying to be cautious but requiring fringe as a baseline is not in the spirit of the codes.


Most Building Departments will/do not enforce the ADA. You need to know it as a designer but Local Jurisdictions my not accept it. 
To avoid lawsuits, A designer needs to design to the most restrictive for the area.


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## tmurray (Jan 18, 2021)

instantmessenger said:


> Interesting, ADA 2010 Standards 213.2 Toilet Rooms and Bathing Rooms, Exception 4:
> Where multiple single user toilet rooms are clustered at a single location, *no more than 50 percent* of the single user toilet rooms for each use at each cluster shall be required to comply with 603.



The key is in the word "required". Reading this sentence in isolation, I would assume another section of the ADA indicates how many are required based on another factor (occupant load, number of facilities, etc.). The quoted sentence then limits the maximum number required to be compliant to not more than 50%.

As Mark pointed out, local AHJs are not usually empowered to enforce federal laws. Knowledge of the pertinent laws are the responsibility of the designer.


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## Paul Sweet (Jan 18, 2021)

Instantmessenger, the IBC exceeds ADA standards in several cases.  You could request a code modification to go to no more than 50%.


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## ADAguy (Jan 19, 2021)

instantmessenger said:


> Huh? So you "guess" it could be interpreted that way, but you don't "think" that was the intent? You "feel" IBC has more clarity? These are all your personal interpretations.
> 
> ADA Standards were written that way for a very specific reason. Whether you agree with it or not, that is exactly the intent.


Standards were written to be a "minimum", exceeding them is allowed and recommended.


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## mark handler (Jan 21, 2021)

ADAguy said:


> Standards were written to be a "minimum", exceeding them is allowed and recommended.


Or a maximum.....


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