# Need some flexibility with plumbing fixtures vs gender



## Yikes (Sep 9, 2016)

I'm sure this could make for some good jokes and "smh" responses, but this is a serious code question.
I am designing a drop-in facility for homeless transitional age youth in the Los Angeles area.  It includes meeting and A-3 recreation rooms, mental health/counseling, job placement, etc.  Occupant load will be over 100 people.

This part of the country still gets a lot of late teens / young adults who ditch their hometowns, thinking they can find stardom in Hollywood, but they end up on the streets.  Some of them are escaping abusive situations, some have mental health issues, and I high number are struggling with their identity, including gender/sexuality issues.  All of this to say that the facility operator does not think it is best to provide traditional multi-user, male-female restrooms.  A better alternative for their clients is to provide a number of single-accommodation restrooms that are gender-neutral, as this is one less issue for them to work through as they seek help for perhaps the first time.

The code problems:
The way that CPC 422.1 is currently written, it appears I must designate a certain number of fixtures for males, and a certain number for females.  CPC 422.2 also requires separate facilities for each sex.  Table 422.1 requires some urinals in male-designated restrooms.
What code mechanism could I use to justify a series (perhaps 4-6) of single accommodation (1 sink, 1 toilet, no urinal) restrooms to serve the A-3 assembly space instead of traditional male-female restrooms?

For sake of discussion, let's assume that I can get an overall fixture count (of all these individual single accommodation rooms) to add up to the equivalent number as would have been required for a traditional toilet facility; so quantity of fixtures is not an issue; assignment of fixtures by sex, and the absence of urinals, is the only issue.

How do I approach asking the building official to let each user have their own private toilet and sink?


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## mtlogcabin (Sep 9, 2016)

The code requires a certain number of water closet fixtures based on the total occupant load. This number is then divided equally for male and female. The male is then allowed to substitute a urinal for a water closet for 50% of the required number of water closets

The code does not require urinals be installed. The code does not require the water closets be located in one room for each sex.

If you can provide the overall fixture count in individual restrooms you have met the code


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## north star (Sep 9, 2016)

*% ~ % ~ %*


Yikes,

In your overall fixture count, are you also counting \
adding the ADA required fixtures to the mix ?....The
owners "could" always go above the code required
minimums and add more fixtures.


*% ~ % ~ %*


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## ICE (Sep 9, 2016)

Definitely not my area of expertise but there may be a Green Code or two when it comes to urinals since they use less aqua.


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## Yikes (Sep 9, 2016)

north star, we would make all single accommodation rooms ADA compliant.


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## mark handler (Sep 10, 2016)

Section 422.1, 2013 CPC, refers to Table  422.1, for the minimum number of plumbing fixtures (water
closets, *urinals,* lavatories and drinking fountains). 

CA Table 422.1, Minimum Plumbing Fixture ‐  
footnote 3‐ A and E occupancies with an occupancy load of less than 50 do not require a second water closet in single occupancy toilets for "potty parity".  
footnote 4‐ The Authority Having  Jurisdiction may approve alternative designs criteria when determining the minimum number of plumbing fixtures


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## Yikes (Sep 12, 2016)

Follow-up question:
CPC 422.1 says: "Where applying the fixture ratios in Table 422.1 results in fractional numbers, such numbers shall be rounded to the next whole number. *For multiple occupancies, fractional numbers shall be first summed and then rounded to the next whole number*.

But when you look at the table, how is it possible to develop a fractional number in the first place, in order to sum them and then round up?  All the numbers in the table are whole number.  *How does this table generate fractions*?

Example: 
1.  Let's say we have 60 females in an A-3 use (female toilets at 3:51-100 occ).  Does that mean we need 3 toilets exactly, or 2.1 toilets which gets rounded up to 3 toilets?
2.  In the adjacent rooms, we have 5 females in a B use (female toilets at 1:1-15).  Does that mean we need 1 toilets exactly, or 0.3 toilet which gets rounded up to 1 toilet?
3.  When designing toilets to simultaneously serve both the A and the B occupancy in the example above, is the required fixture count calculated as:
a)  3+1 = 4 toilets?
b) 2.1+0.3 = 2.4 ~ round up to 3 toilets?​


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## JBI (Sep 12, 2016)

The table does not generate fractions, the occupant load might. If the table says 1 per 50 occupants, and you have 60 occupants, the 10 occupants left over could be combined with the remainders from the other areas rather than round up for each occupancy/use area. It's a pretty sensible approach actually. 
The local AHJ should be involved in the discussion. 
Also, if it is an existing building you may be able to use Chapter 34 or the EBC, whichever applies, to come up with alternatives as well.


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## Yikes (Sep 12, 2016)

JBI said:


> If the table says 1 per 50 occupants, and you have 60 occupants, the 10 occupants left over could be combined with the remainders from the other areas rather than round up for each occupancy/use area.


If I were to sum the remainder occupants from A occ. + B occ., which ratio from the table 422.1 would would I apply to that sum: the A occupancy toilet ratio, or the B occupancy toilet ratio?


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## north star (Sep 12, 2016)

*@ = @ = @*



> *Example:*
> *1. Let's say we have 60 females in an A-3 use (female toilets at*
> *3:51-100 occ).     Does that mean we need 3 toilets exactly,*
> *or 2.1 toilets which gets rounded up to 3 toilets?*
> ...




*@ = @ = @*


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## JBI (Sep 12, 2016)

Yikes said:


> If I were to sum the remainder occupants from A occ. + B occ., which ratio from the table 422.1 would would I apply to that sum: the A occupancy toilet ratio, or the B occupancy toilet ratio?



I would say whichever gives you the higher number of fixtures (although they should be within one fixture or so...).


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## tmurray (Sep 13, 2016)

Yikes said:


> I'm sure this could make for some good jokes and "smh" responses, but this is a serious code question.
> I am designing a drop-in facility for homeless transitional age youth in the Los Angeles area.  It includes meeting and A-3 recreation rooms, mental health/counseling, job placement, etc.  Occupant load will be over 100 people.
> 
> This part of the country still gets a lot of late teens / young adults who ditch their hometowns, thinking they can find stardom in Hollywood, but they end up on the streets.  Some of them are escaping abusive situations, some have mental health issues, and I high number are struggling with their identity, including gender/sexuality issues.  All of this to say that the facility operator does not think it is best to provide traditional multi-user, male-female restrooms.  A better alternative for their clients is to provide a number of single-accommodation restrooms that are gender-neutral, as this is one less issue for them to work through as they seek help for perhaps the first time.
> ...



I just did a youth center and faced the gender identity issue here as well. Luckily, we have a performance based code and while the code does require male and female washrooms, it is required for sanitary reasons and there appears to be no justification on why a male or female washroom would be required and unisex with the same number of fixtures prevented, so we accepted their proposal for unisex washrooms.

To be completely honest, I feel like this decision should be left to the owner. The building official should regulate the number of fixtures, but how they are apportioned should be up to the company because no one knows their clients like they do.


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## Yikes (Sep 14, 2016)

tmurray, thanks for sharing your own experience.  And just to be extra-clear, we are not proposing a multi-user unisex restroom.  We are proposing an equivalent number of gender-neutral single-occupancy rooms, each with its own toilet and lav.


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## mtlogcabin (Sep 14, 2016)

Unisex would still be the correct label for the door. Does not matter what a person thinks or feels about their gender. They are one or the other, can't claim to be neutral by definition of the word.


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## tmurray (Sep 16, 2016)

mtlogcabin said:


> Does not matter what a person thinks or feels about their gender. They are one or the other, can't claim to be neutral by definition of the word.



As soon as I get to work, I don't care because tax paying citizens are not paying me to care. They are paying me to make sure buildings are safe and meet municipal laws. My personal opinions do not matter and it would be unethical to force my personal beliefs on anyone else as I am in a position of authority.


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## conarb (Sep 17, 2016)

tmurray said:


> As soon as I get to work, I don't care because tax paying citizens are not paying me to care. They are paying me to make sure buildings are safe and meet municipal laws. My personal opinions do not matter and it would be unethical to force my personal beliefs on anyone else as I am in a position of authority.


T Murray:

Too bad everyone here didn't think like you do, some here spend hours per day posting stuff like ADA, obviously they are trying to recruit others into their personal agenda, makes me wonder how they run their their departments.


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## tmurray (Sep 19, 2016)

conarb said:


> T Murray:
> 
> Too bad everyone here didn't think like you do, some here spend hours per day posting stuff like ADA, obviously they are trying to recruit others into their personal agenda, makes me wonder how they run their their departments.



Our version of ADA is actually built right into our code, I actually enforce it. New buildings must meet the requirements. Old buildings... well we get as close as reasonable given technical limitations. I do find it humorous that the US has a much stronger law protecting the disabled than a socialist nation such as Canada.


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## JBI (Sep 19, 2016)

Socialist nations, like Canada, have not abandoned the concept of the social compact between businesses and people. Here in the USA, for owners, it's all about the bottom line.


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## steveray (Sep 23, 2016)

Men's and women's are required.....Or a waiver, however that works in your AHJ...

2902.2 Separate lfalCulliltnes. Where plumbing fixtures are required,
separate facilities shall be provided for each sex.
lExceptnoH1ls~
1. Separate facilities shall not be required for private facilities.
2. Separate employee facilities shall not be required in
occupancies in which 15 or fewer people are employed.
3. Separate facilities shall not be required in structures or
tenant spaces with a total occupant load, including
both employees and customers, of 15 or less.
4. Separate facilities shall not be required in mercantile
occupancies in which the maximum occupant load is
50 or less.


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## mtlogcabin (Sep 23, 2016)

tmurray said:


> My personal opinions do not matter and it would be unethical to force my personal beliefs on anyone else as I am in a position of authority.


I agree and the code only refers to male, female and neutral genders. Anything else is a social issue.


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## Iwant2knowwhy (May 28, 2020)

mtlogcabin said:


> The code requires a certain number of water closet fixtures based on the total occupant load. This number is then divided equally for male and female. The male is then allowed to substitute a urinal for a water closet for 50% of the required number of water closets
> 
> The code does not require urinals be installed. The code does not require the water closets be located in one room for each sex.
> 
> If you can provide the overall fixture count in individual restrooms you have met the code



Is a Urinal required by code? I have read and reread 
SPS 362.2900 Additional criteria for toilets. These are department rules in addition to the requirements in IBC chapter 29:
and I understand it that a urinal may replace up to 50% of WC. Building inspector says I must have one and refers to this code but 2% of my business is male.


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## Iwant2knowwhy (May 28, 2020)

Iwant2knowwhy said:


> Is a Urinal required by code? I have read and reread
> SPS 362.2900 Additional criteria for toilets. These are department rules in addition to the requirements in IBC chapter 29:
> and I understand it that a urinal may replace up to 50% of WC. Building inspector says I must have one and refers to this code but 2% of my business is male.



I have occupancy of 81, Business, one restroom or each sex, two toilets each. I just want to be specific because he is not giving in. Thank you for your time, knowledge and willingness to assist others.


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## classicT (May 28, 2020)

Iwant2knowwhy said:


> Is a Urinal required by code? I have read and reread
> SPS 362.2900 Additional criteria for toilets. These are department rules in addition to the requirements in IBC chapter 29:
> and I understand it that a urinal may replace up to 50% of WC. Building inspector says I must have one and refers to this code but 2% of my business is male.


I believe that your inspector is wrong. See the red text below and note the use of the word "may".

*SPS 362.2902 Plumbing fixtures.*
(1)  Minimum number of fixtures.
(a) Exceptions. These are department exceptions to the requirements in IBC section 2902.1:
1. Where more than one water closet is required for males, urinals may be substituted for up to 50 percent of the required number of water closets, except that urinals may be substituted for up to 67 percent of the required number of water closets in Group A and E occupancies.
2. Where drinking fountains are required, other reasonable alternatives are acceptable, as approved by the department.
3. For child day care facilities, bathtubs or showers are not required where other personal hygiene washing arrangements are provided that satisfy the licensing requirements of the Wisconsin department of health services.
4. For day nurseries and child day care facilities, children under the age of 30 months need not be considered as a part of the occupant load used to determine the minimum number of water closets.
5. Service sinks may be omitted for any occupancy where privies have been substituted for water closets under s. SPS 362.2900 (1) (a) 2.​(b) Additional fixtures. These are department informational notes to be used under IBC sections 2902.1 and 2902.2: Note: Additional plumbing fixtures may be required for employees by the U.S. department of labor, occupational safety and health act (OSHA) regulations.
Note: Additional plumbing fixtures may be required by the department of health services for restaurants, mobile home parks, camping grounds, camping resorts, recreational camps and educational camps.
Note: Chapter SPS 390 also has requirements for minimum numbers of sanitary fixtures for a public swimming pool, as based on the pool area. For some buildings, the minimum number of sanitary fixtures determined in that manner may be larger than the minimum number determined in accordance with this section. Compliance with this section does not relieve an owner from complying with ch. SPS 390.
Note: Chapter SPS 391 has requirements for equal speed of access to toilets for each gender, at facilities where the public congregates that do not fall under the scope of this chapter.​(c) Substitutions in IBC Table 2902.1.
1. Substitute the following wording for the water closets heading in IBC Table 2902.1: Water closetse (see s. SPS 362.2902 (1) (a) 1. for urinals).
2. Substitute the following wording for the drinking fountains heading in IBC Table 2902.1: Drinking fountains (see s. SPS 362.2902 (1) (a) 2.).
3. In IBC Table 2902.1, substitute the following wording for the required minimum number of water closets for females in type A-4 and A-5 occupancies: 1 per 37 for the first 1,500 and 1 per 60 for the remainder exceeding 1,500.
4. Substitute the following wording for the required number of bathtubs or showers in storage occupancies in IBC Table 2902.1: See the International Plumbing Code.
5. Substitute the following wording for the required number of bathtubs or showers in factory and industrial occupancies in IBC Table 2902.1: See the International Plumbing Code.​(d) Addition to IBC Table 2902.1. This is an additional department footnote for IBC Table 2902.1: Footnote e. Wherever more than 500 people congregate and more than the required minimum number of water closets or urinals are provided for males, twice as many of those additional toilet facilities shall be provided for females.
(e) Alternative to IBC Table 2902.1. This is a department alternative to the minimum fixture requirements of IBC Table 2902.1: The required number of toilet fixtures may be based on the actual occupancy load rather than the load determined by square footage per IBC Table 1004.1.1. The actual occupancy load shall be based on justification found acceptable to the department.​


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## mtlogcabin (May 28, 2020)

your inspector is wrong


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## steveray (May 28, 2020)

2018 update.....2902.1.2 now gets you out of the M/F in single users...

required plumbing fixtures for a building or tenant space.
Single-user toilet facilities and bathing rooms, and family
or assisted-use toilet rooms and bathing rooms shall be
identified for use by either sex.

And you can get out of some accessibility...

3. Where multiple single-user toilet rooms or bathing
rooms are clustered at a single location, at least 50
percent but not less than one room for each use at
each cluster shall be accessible.


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## Sifu (May 28, 2020)

steveray said:


> 2018 update.....2902.1.2 now gets you out of the M/F in single users...
> 
> required plumbing fixtures for a building or tenant space.
> Single-user toilet facilities and bathing rooms, and family
> ...



Interesting.  I wasn't interpreting this section that way.  When it says "either sex" I don't read it as "both", therefore it must be _either _M or F, and adhere to the required number for each.  The commentary doesn't really help, but it does give several examples, all of which indicate that each room must be _either _M or F.  But I do see a little ambiguity here.  Might be a good candidate for an interpretation if one hasn't already been asked for.


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## steveray (May 29, 2020)

ICC is attempting to keep up with the gender fluid/ neutral movement....2021 may clear it up more...Maybe it will say "any gender or lack thereof"...


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## mtlogcabin (May 29, 2020)

You do have to adhere to the required number for each and you have to round up to achieve the correct number. The big mistake I have seen is the designer wants to include a urinal in the same single user water closet room and have it count as one of the required fixtures. I do not allow it because logically the room is used by one person at a time.


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## mtlogcabin (May 29, 2020)

No back to the original post about is a urinal required. It might be locally or state amendment. Our state requires a urinal in addition to the 1st water closet for places that serve food and/or drink. 

g. Food service establishments or any establishment that sells alcoholic beverages for on-site consumption requires at least one urinal


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## classicT (May 29, 2020)

mtlogcabin said:


> No back to the original post about is a urinal required. It might be locally or state amendment. Our state requires a urinal in addition to the 1st water closet for places that serve food and/or drink.
> 
> g. Food service establishments or any establishment that sells alcoholic beverages for on-site consumption requires at least one urinal


Washington State has a similar amendment; however, Wisconsin does not have a similar amendment. See SPS 362.2902 as follows.


Ty J. said:


> *SPS 362.2902 Plumbing fixtures.*
> (1)  Minimum number of fixtures.
> (a) Exceptions. These are department exceptions to the requirements in IBC section 2902.1:
> 1. Where more than one water closet is required for males, urinals may be substituted for up to 50 percent of the required number of water closets, except that urinals may be substituted for up to 67 percent of the required number of water closets in Group A and E occupancies.
> ...


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## rgrace (Jun 9, 2020)

steveray said:


> ICC is attempting to keep up with the gender fluid/ neutral movement....2021 may clear it up more...Maybe it will say "any gender or lack thereof"...



Steveray, you are correct. The 2021 IBC/IPC will read this way:

*2902.1.2 Single-user toilet and bathing room fixtures. *The plumbing fixtures located in single-user toilet and bathing rooms, including family or assisted use toilet and bathing rooms that are required by Section 1109.2.1 of the International Building Code, shall contribute toward the total number of required plumbing fixtures for a building or tenant space. Single-user toilet and bathing rooms, and family or assisted-use toilet rooms and bathing rooms shall be identified as being available for use by all persons regardless of their sex.
(also note this important addition)
The total number of fixtures shall be permitted to be based on the required number of separate facilities or based on the aggregate of any combination of single-user or separate facilities.

This is a path Yikes can follow through a code mod process, and as syeveray also pointed out, number 3 from IBC 1109.2 can be used for accessibility compliance (not all single-user toilet rooms will have to be accessible if clustered together).

1109.2, #3. Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50 percent but not less than one room for each use at each cluster shall be accessible.


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## ADAguy (Jun 19, 2020)

conarb said:


> T Murray:
> 
> Too bad everyone here didn't think like you do, some here spend hours per day posting stuff like ADA, obviously they are trying to recruit others into their personal agenda, makes me wonder how they run their their departments.



Not my agenda, only acknowledging the law which benefits us all.


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## ADAguy (Jun 19, 2020)

rgrace said:


> Steveray, you are correct. The 2021 IBC/IPC will read this way:
> 
> *2902.1.2 Single-user toilet and bathing room fixtures. *The plumbing fixtures located in single-user toilet and bathing rooms, including family or assisted use toilet and bathing rooms that are required by Section 1109.2.1 of the International Building Code, shall contribute toward the total number of required plumbing fixtures for a building or tenant space. Single-user toilet and bathing rooms, and family or assisted-use toilet rooms and bathing rooms shall be identified as being available for use by all persons regardless of their sex.
> (also note this important addition)
> ...



Spot on, this is what I have been looking for. As to 50% if they are all ganged to a single entrance couldn't you then differ to ADA minimums of one accessible WC and 1 ambulatory if exceeding 6 fixtures  (or do all GN's have to then each be accessible?). The only issue would then be urinals ( gender neutral enclosures or not?) Lavs could be shared in common. How would you do signage for the unaccessible GN's?


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## mark handler (Jun 19, 2020)

*In CALIFORNIA, *
URINALS *are required* per:
2019 CALIFORNIA PLUMBING CODE TABLE 422.1 MINIMUM PLUMBING FACILITIES
URINALS are required in:
Assembly occupancies, Business occupancies, Educational occupancies, Some Institutional occupancies, Some Mercantile occupancies, some R-2occupancies.


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