# Mezzanine with a shower



## classicT (May 29, 2020)

Given: One story PEMB with a mezzanine. Two single occupant restrooms with toilet/lav only on the main floor. Mezzanine also has a restroom that includes a shower.

Given Section 1109.2, I indicated to the applicant that the only shower within the space could not be on an inaccessible floor, as the mezzanine is not on an accessible route (>3000sf; Sec. 1104.4 #1).

They are now proposing that the bathing facility is accessed through a private office, and therefore falls under exception #1 of 1109.2. Getting some push back that it doesn't have to be on an accessible route where accessed via a private office per the exception. My thought is that the exception only allows the exceptions allowed per A117.1 (i.e. no grab bars, removable cabinet under sink, etc.).

Thoughts?

*1109.2 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 1109.2.2 and 1109.2.3, at least one of each type of fixture, element, control or dispenser in each accessible toilet room and bathing room shall be _accessible_.
Exceptions:

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.
...


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## khsmith55 (May 29, 2020)

I would caution using the "private office" exception since it has to be able to be made accessible. Therefore you should provide ALL the maneuvering clearances for the future, you may also want to use an accessible toilet, sink and shower for future use. Blocking for future grab bars is also required. Given all the requirements for "future" accessibility it may be easier to make it accessible now. An often misunderstood concept is that restrooms on non-assessible levels don't have to be accessible (except for the private office exception), this is incorrect.

Ken


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## classicT (May 29, 2020)

khsmith55 said:


> I would caution using the "private office" exception since it has to be able to be made accessible. Therefore you should provide ALL the maneuvering clearances for the future, you may also want to use an accessible toilet, sink and shower for future use. Blocking for future grab bars is also required. Given all the requirements for "future" accessibility it may be easier to make it accessible now. An often misunderstood concept is that restrooms on non-assessible levels don't have to be accessible (except for the private office exception), this is incorrect.
> 
> Ken


Totally agree, and they are actually using all accessible use fixtures. Bathroom complies with accessibility requirements. The issue at hand is that it is the only shower and it is not on an accessible route.


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## khsmith55 (May 30, 2020)

Discounting the "private office" exception, if a shower is provided it MUST be accessible, even if the shower is not required.

Ken


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## steveray (Jun 1, 2020)

I don't think there is any exception in ANSI for the shower....W/C and lav there are.....

Grab bars and seat are exempt, nothing else...


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## classicT (Jun 1, 2020)

khsmith55 said:


> Discounting the "private office" exception, if a shower is provided it MUST be accessible, even if the shower is not required.
> 
> Ken





steveray said:


> I don't think there is any exception in ANSI for the shower....W/C and lav there are.....
> 
> Grab bars and seat are exempt, nothing else...


No issues with the shower being accessible. As indicated, all fixtures and the room will be accessible.

Issue is that they are on a mezzanine that is not served by an accessible route.


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## steveray (Jun 1, 2020)

Got it....No exception from the route....Just the room design per Ex.1....I usually explain it to people that the bathroom in "bob's" office is exempt, but when bob gets hit by a bus tomorrow, you don't have to rebuild the building or bathroom to make it accessible...


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## ADAguy (Jun 1, 2020)

steveray said:


> I don't think there is any exception in ANSI for the shower....W/C and lav there are.....
> 
> Grab bars and seat are exempt, nothing else...



An ANSI exception is not an exception to ADA compliance.


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