# Cluster of restrooms



## BayPointArchitect (Aug 10, 2018)

For nine years, I have been telling folks that "every restroom needs to be ADA accessible".
And now I am being introduced to the cluster concept for the first time in nine years.
Would everyone else concur with the idea that only two out of four restrooms need to be ADA accessible?
See attachment.

Thanks

ICC Certified Plan Reviewer
NFPA Certified Fire Plan Examiner


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## steveray (Aug 13, 2018)

I would have to have that discussion as to whether or not I would consider that a cluster as they are not "line of sight"  or "adjacent IMO....at a min you would need signage directing to the accessible ones....


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## mark handler (Aug 13, 2018)

I agree with steveray on questioning the cluster. I might consider this in a remodel, but would not in new construction.
ADASAD - A water closet in a toilet room for a single occupant *accessed only through a private office* and not for common use or public use shall not be required to comply with the accessibility codes.


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## BayPointArchitect (Aug 13, 2018)

thanks!

As for the "private office" exception, the interpretation that I received from the DOJ is that grab bars may be installed later and front panel of lavatory may be removed if the restroom needs to be "adapted".  Well, that is not the same as "not required to comply".  Adequate floor space isn't something you can add later with a simple screw driver.


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## mark handler (Aug 13, 2018)

BayPointArchitect said:


> thanks!
> 
> As for the "private office" exception, the interpretation that I received from the DOJ is that grab bars may be installed later and front panel of lavatory may be removed if the restroom needs to be "adapted".  Well, that is not the same as "not required to comply".  Adequate floor space isn't something you can add later with a simple screw driver.


The requirements for the "private office" changed in 2010 ADASAD


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## Pcinspector1 (Aug 13, 2018)

BayPointArchitect said:


> Adequate floor space isn't something you can add later with a simple screw driver.



I believe you would have to provide adequate floor space, be able to install grab bars as well as providing the required toilet height and below sink protection when providing a private BRM for a B-occupancy office space.

Grab bar wall backing would or could be enforced at rough-in stage?


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## ADAguy (Aug 13, 2018)

Note that accessible RR doors do not open to the corridor vs the non-accessible RRs.


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## georgia plans exam (Aug 13, 2018)

BayPointArchitect brings up a very good question. What is a cluster? Although the advisory portion of Section 213.2 in the 2010 ADASAD seems to be a reasonable interpretation of the term "cluster" (within sight of, adjacent to), it is only advisory.
If one designer chooses to place 5 required water closets into one restroom, only 1 would be required to be accessible. If another chooses 5 toilet rooms for the same occupant load, all would be required to be accessible unless they were "clustered at a single location". It is open to interpretation.   GPE


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## ADAguy (Aug 13, 2018)

Points noted, as usual, "it depends" on how it is presented to the AHJ and their interpretation.
Another unanswered performance question relates to distance to/between facilities, comments anyone? Any time to distance studies for wheelchairs vs ambulatory folks?


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## rgrace (Aug 13, 2018)

We have formed our own interpretation for "clustered" as used in Exception 3 of IBC 1109.2 that states where three or more single-occupant toilet rooms and/or bathing rooms are located either adjacent to or across the hall from each other with a maximum of 20 feet travel distance from center of door to center of door. We developed this interp from the following:

The International Code Council (ICC) does not have a clear definition for the word "clustered" as used in Exception 3 of IBC 1109.2. A passage taken from _Accessible Single-Occupant Bathrooms _by Kimberly Paarlberg, ICC Senior Staff Architect, states:

""Clusters" are toilet rooms accessed from the same area or space, not toilet rooms dispersed throughout an area" (pg. 2) and "where several single-occupant bathrooms would be clustered immediately adjacent to or across the hall from one another" (pg. 2).


This passage, or opinion, makes clear that where three or more single-occupant toilet/bathing rooms are placed side-by-side, or where placed across a hall from one another, this can be considered "clustered". We have defined the distance for "across a hall" as twenty feet (20’) based on the allowable widths shown in IBC Table 1018.2 "Minimum Corridor Width"

Georgia, thanks for the Section 213.2 in the 2010 ADASAD


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## BayPointArchitect (Aug 13, 2018)

I like the 20 feet limit.  Along that same line of thinking, I often tell folks that the "private office" exception does not apply to a room with more than 200 square feet.  Especially if the plans show a conference table - or reception desk - or more than one desk.  In my opinion, that is an office built for two or more people and does not fit the example of a CEO's private powder room.

Georgia, when you say, "it is only advisory" it makes me believe that these "requirements" are not really required.  I am confused.  What is meant by "advisory"?


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## ADAguy (Aug 13, 2018)

Advisory as in a suggestion, a "best" practice, lacks the force of law.


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## georgia plans exam (Aug 13, 2018)

From the Guidance on the 2010 ADA Standards for Accessible Design.

"The Department also wishes to clarify that the advisory notes, appendix notes, and figures that accompany the 1991 and 2010 Standards do not establish separately enforceable requirements unless specifically stated otherwise in the text of the standards."


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## georgia plans exam (Aug 13, 2018)

BPA - I do not think that there is a size limit to a private office, although I agree that if the plans indicate other than a private office I would treat it as such.  GPE


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