# Reduced fixture cout to meet ADA?



## mtlogcabin (Aug 3, 2011)

Just curious how many would allow the elimination of a water closet or urinal in order to achieve ADA compliance?

Example existing restaurant wants to make the restrooms accessible but the only way is to add to the exterior of the building without relocating the main entrance or the kitchen area. OL requires 2.25 water closets, traditionally we round up. Has anybody considered rounding down and removing one. It is not "technically infeasible" to relocate the main entrance or kitchen or add to the exterior just darned expensive. What documentation would you like to see in the file to back up such action if you allowed less then the minimum fixture count.


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## codeworks (Aug 3, 2011)

Lower the number of permitted occupants in the building. Thats where the numbers of required fixtures come from , right?


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## Papio Bldg Dept (Aug 3, 2011)

i overheard a little bird say once, that code numbers that end in zero are usually arbitrarily defined (no to little scientific basis/reasoning).  not sure if it is true or not, but I might also have heard allowable areas tabulations were simply defined from surveys of california building departments.

At any rate, there are provisions in the code for acceptance of alternative designs, and if lowering the occupant load is not an option, then sections 2902.1, which allows the occupancy to be considered by the building official, and 2902.3, which allows for statistical data alternatives for numbers of each sex, should give you enough flexibility to adjust your plumbing fixture counts.  Chapter 10 also gives you some flexibility in occupant load reductions as codeworks stated.

I would definitely give it reasonable consideration, but would need more information regarding the accessibility requirement trying to be avoided.


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## alora (Aug 3, 2011)

Papio Bldg Dept said:
			
		

> ... At any rate, there are provisions in the code for acceptance of alternative designs, and if lowering the occupant load is not an option, then sections 2902.1, which allows the occupancy to be considered by the building official, and 2902.3, which allows for statistical data alternatives for numbers of each sex, should give you enough flexibility to adjust your plumbing fixture counts. ...


Unless this restaurant is in San Francisco or has some pole-dancing involved, a person may be hard-pressed to provide statistical data proving that significantly more men than women may be present.


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## mtlogcabin (Aug 3, 2011)

codeworks said:
			
		

> Lower the number of permitted occupants in the building. Thats where the numbers of required fixtures come from , right?


kind of hard to do since it is fixed booth seating. I guess they could remove some


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## mtlogcabin (Aug 3, 2011)

> but would need more information regarding the accessibility requirement trying to be avoided.


It is a family pizza joint that was built and been family run since the early 1980's. They are just trying to do what is right without having a major expense. Except for after high school football and basketball games I bet they never exceed 80% OL


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## Examiner (Aug 3, 2011)

"technically infeasible" is not a term based on money or adding footage.  It is a term based on structural implications.  Very hard to prove it is technically infeasible to provide accessible restrooms.  You could use some of the area inside the building and loose seating?


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## Papio Bldg Dept (Aug 3, 2011)

alora said:
			
		

> Unless this restaurant is in San Francisco or has some pole-dancing involved, a person may be hard-pressed to provide statistical data proving that significantly more men than women may be present.


The statistical data is often provided for new stadium designs where the 1 per 40 for women is disproportionate compared to the 1 per 75 for men in an A-4 occupancy.  I doubt 2902.3 is in the code to not be used, hard-pressing or difficult it may be in another issue to be determined by the Building Official of the AHJ.

An A-2, with an occupant load of 336 occupants would require 2.25 toilet fixtures per male and female according to Chapter 29 of the IBC.  A reduction of the occupant load to 300 would get you down to 2 toilet fixtures per sex.


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## alora (Aug 3, 2011)

Excerpt from DOJ 2010 Standards, page 48.



> Technically Infeasible. With respect to an alteration of a building or a facility, something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.


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## Papio Bldg Dept (Aug 3, 2011)

Examiner said:
			
		

> "technically infeasible" is not a term based on money or adding footage.  It is a term based on structural implications.  Very hard to prove it is technically infeasible to provide accessible restrooms.  You could use some of the area inside the building and loose seating?


I agree with Examiner on this one, and would recommend staying away from the "technically infeasible" argument.  It is hard to justify, and is not, in my opinion (which are like elbows on a centipede), the best way to approach this.  Find a way, there seem to be multiple options available under the IBC/IEBC/IPC, to reduce your fixture counts so that a renovation can make the restrooms accessible.


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## north star (Aug 3, 2011)

*& & & &*





> *They are just trying to do what is right without having a major expense.*


In my experience [ IME ], doing the right thing will usually mean "having extra expense(s)"!

*& & & &*


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## Pcinspector1 (Aug 3, 2011)

Did you count the pony ride and two seater helicopter as seating?

I would'nt

pc1


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## mtlogcabin (Aug 4, 2011)

Well zoning said no on expanding due to setback requirements and relocating the front entrance will reduce seating capacity but not quite enough. Will meet later today to discuss other options.


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## north star (Aug 4, 2011)

*& & & &*

What about having the business owner apply for a variance

for relief from the setbacks?

*% % % %*


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## Papio Bldg Dept (Aug 4, 2011)

accessboard webinar just said that technical feasability would apply when removal of toilet stall is not permitted by plumbing code.  cool huh?  download the powerpoint for recreational and fitness centers.  slide 20 or 21.


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## mtlogcabin (Aug 4, 2011)

> technical feasability would apply when removal of toilet stall is not permitted by plumbing code


My thought is the plumbing code numbers should be flexible to accomodate acessibility issues in existing buildings. Cost should play into the equation. This is an existing 35 year plus business that was only required to remove barries under the ADA which they did. Now for what ever reason they are asking about making the restrooms fully compliant and the requirements are expand the building, relocated your main entrance which will loses seating and reduce revenues forever or remove seating. Honestly how many of you have waited inline to uses a rest room with multiple fixtures in a family oriented restuarant.

Will meet onsite in about 30 minutes and see what can be done.


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## Papio Bldg Dept (Aug 5, 2011)

How did it turn out?


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## mtlogcabin (Aug 9, 2011)

Finally got on site. Owners decided instead of spending money on relocating the main entrance they would change out the interior booth seating for tables and chairs and expand the salad bar area.

I will use the exception to 1004.1.1 Areas without fixed seating and establish a design occupant load that will comply with the reduced fixture count instead of a calculated occupant load. About 22 less is all that is needed

Exception: Where approved by the building official , the actual number of occupants for whom each occupied space, floor or building is designed, although less than those determined by calculation, shall be permitted to be used in the determination of the design occupant load .


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