# Type B sleeping unit



## Sifu (Oct 19, 2020)

Does the IBC or ANSI standard require the installation sanitation facilities within a type B sleeping unit?  Or, do the regulations for sleeping unit facilities require compliance if they are provided?

The question centers around a submittal I received for an assisted living facility in a residence that proposed non-accessible sanitation (water closet, lav, shower) within each sleeping unit.  The latest proposal is to only provide an accessible half-bath (water closet and lav).  I don't think the IBC scopes any, but _if provided_ must meet the requirements.  I think the state licensing requirements scope the minimum sanitation, based on the number of beds, thus they are provided.)


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## RLGA (Oct 19, 2020)

Assisted living facilities are Group I-1 and require Accessible and Type B units per IBC Section 1107.5.1. Depending on what Group I-1 condition applies, the number of Accessible units will be either 4% or 10%. Section 1107.5.1 refers to the units as either _dwelling units_ or _sleeping units_. If they are dwelling units, then all of these elements are present: sleeping, living, eating, cooking, and sanitation. If they are sleeping units, then only sleeping provisions are required, but they may contain elements for living, eating, and either kitchen or sanitation, but not both. The units you describe sound like either dwelling units (all elements provided) or sleeping units (all elements provided, but no kitchens, since sanitation facilities are provided).

For Accessible units, ANSI A117.1, Section 1002.11, requires at "least one toilet and bathing facility" to comply with Section 1002.11.2, which requires the one facility to comply with Section 603. It must include "one lavatory, one water closet and *either a bathtub or shower within the unit*." For Type B units, ANSI A117.1, Section 1004.11.3 requires either all "toilet and bathing facilities" to comply with Option A or one to comply with Option B--both require either a bathtub or shower.

So, in short, if they are provided, then they must be accessible for Accessible units or of limited accessibility for Type B units. If they do not want to provide the required accessible sanitation facilities in the units, then they must remove them, call the units sleeping units, and provide accessible community sanitation facilities.


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## Sifu (Oct 19, 2020)

Yes, sleeping units within an assisted living facility.  State scoping requires compliance with FGI, which would require the toilet rooms  be accessed without going through a corridor (no bathing).  So the state is scoping the toilet rooms, and since they are provided those must meet the appropriate level of access.  Thanks for the reply, it confirms my thoughts.


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## RLGA (Oct 19, 2020)

Sifu said:


> Yes, sleeping units within an assisted living facility.  State scoping requires compliance with FGI, which would require the toilet rooms  be accessed without going through a corridor (no bathing).  So the state is scoping the toilet rooms, and since they are provided those must meet the appropriate level of access.  Thanks for the reply, it confirms my thoughts.


If they are providing toilet rooms within the sleeping units, they must also provide a bathtub or shower.


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## Sifu (Oct 20, 2020)

RLGA said:


> If they are providing toilet rooms within the sleeping units, they must also provide a bathtub or shower.


Now you lost me.  There is a fully accessible toilet and bathing room available on each floor for all residents.  Is that the issue?  If not, where does that requirement come from?


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## RLGA (Oct 20, 2020)

Sifu said:


> Now you lost me.  There is a fully accessible toilet and bathing room available on each floor for all residents.  Is that the issue?  If not, where does that requirement come from?


This is per ANSI A117.1, Section 1002.11, as I quoted previously for Accessible Units. This section requires at "least one toilet and bathing facility" (this is saying it is a single facility with both toilet and bathing provisions) to comply with Section 1002.11.2. The "facility" must include "one lavatory, one water closet and *either a bathtub or shower within the unit*."

The requirements for Type B units are similar and are provided in ANSI A117.1, Section 1004.11.3. This section requires either all "toilet and bathing facilities" to comply with Option A or one to comply with Option B--both require either a bathtub or shower in addition to a water closet and lavatory. Since only one bathroom appears to be provided, it really doesn't matter which option you choose, you end up with nearly identical requirements.

Thus, if a _sleeping unit _has sanitation facilities, then all required fixtures must be provided. Just because somewhere in the building there is an accessible toilet and bathing facility does not mean that all sanitation provisions within each sleeping unit are permitted to be non-accessible.


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## Sifu (Oct 20, 2020)

1002.11 is for *A*ccessible units.  These are not* A*ccessible units, they are type B units.  IBC 1107.6.4 for R4 condition 1 facilities requires one Accessible unit and the rest type B units.  There is a fully accessible unit in the building, and a proposed additional fully accessible toilet and bathing room for common use.  I do not see any scoping for individual bathing facilities in the IBC or ANSI.  I do see an exception for rooms that contain only a water closet and lavatory for type B units, leading me to believe it is permitted.  ANSI 1004.11.3 uses "provided", and I don't see scoping for which fixtures there either.  I would need to revisit to make sure but in reading FHAG I am pretty sure I found the same thing.


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## RLGA (Oct 20, 2020)

I stated in my first post that I was assuming this to be a Group I-1, and that was never denied, so I continued with that assumption.

However, the Type B sleeping units are required to provide what amounts to be semi-accessible fixtures per either Option A or Option B. I will concede that for Option A, Section 1004.11.3.1.3 states "Where _provided_..." in regard to bathtubs and showers; and for Option B, Section 1004.11.3.2 states "One of each type of fixture _provided _shall comply..." Thus, it could be interpreted to mean if a bathtub or shower is provided, under either option, then it must comply with Section 1004.11.3.1.3, but neither is necessarily required to be provided.

I assume the exception you mention is for Exception 2 to Section 1004.11.3.1. This exception only applies when the water closet and lavatory are not the only water closet and lavatory in the unit. In the situation you describe, these are the only fixtures within a Type B sleeping unit, so they must comply if using Option A (Option B would require compliance, too).


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## Sifu (Oct 21, 2020)

RLGA said:


> I stated in my first post that I was assuming this to be a Group I-1, and that was never denied, so I continued with that assumption.
> 
> However, the Type B sleeping units are required to provide what amounts to be semi-accessible fixtures per either Option A or Option B. I will concede that for Option A, Section 1004.11.3.1.3 states "Where _provided_..." in regard to bathtubs and showers; and for Option B, Section 1004.11.3.2 states "One of each type of fixture _provided _shall comply..." Thus, it could be interpreted to mean if a bathtub or shower is provided, under either option, then it must comply with Section 1004.11.3.1.3, but neither is necessarily required to be provided.
> 
> I assume the exception you mention is for Exception 2 to Section 1004.11.3.1. This exception only applies when the water closet and lavatory are not the only water closet and lavatory in the unit. In the situation you describe, these are the only fixtures within a Type B sleeping unit, so they must comply if using Option A (Option B would require compliance, too).


I should have been more precise in my OP.  These are bedrooms in an assisted living residence.  12 bedrooms.  My path for this has been per 1107.6.4 where the bedrooms are considered sleeping units.  That being the case, 1 Accessible unit and 11 type B units are required as an R4 condition 1.  This is a 2 level residence with an elevator.  The original proposal was to add 3 bedrooms on the lower level (bringing the total to 12), each with its own toilet and bathing room. that did not meet type B requirements.  The other three lower level were being reconfigured in the same manner.  To complicate matters, 5 of the 6 bedrooms upstairs were permitted without any regard for type B units and are all non-compliant except for 1 fully Accessible unit.  My review said all of the lower level units had to be type B units, which really blew the 3 bed expansion up.  The latest proposal is to have all 6 bedrooms contain toilet rooms per ANSI and FHAG, and have one fully accessible toilet and bathing unit for use by all residences.  I have scoured ANSI, the FHAG and the state licensing/scoping documents (which requires compliance with FGI), and FGI, (which permits toilet rooms in the units and one bathing unit per floor and a minimum of 1/20).  The "where provided" language in ANSI is preventing me form being able to cite the toilet rooms as non-compliant, the FHAG seems to lack clear scoping language too.

The final product will be 6 bedrooms (sleeping units) upstairs, with one fully accessible communal toilet and bathing room and 6 non-compliant toilet and bathing units (1 in each room) and 6 bedrooms downstairs, with one fully accessible communal toilet and bathing unit and 6 compliant powder rooms (1 in each room).

A lot of the commentary points things in the direction of bathing facilities are required in each type B sleeping unit, but I have been hanging my hat on the "where provided" language in all other codes for years and feel like it is a stretch to abandon that now.

Unfortunately, the owners have several of these facilities and have never been made to comply before.....then along comes me.  Though I won't cast too much shade on the previous reviewers because I really think this could all be a little easier to understand.


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