# Public Toilets required?



## Mech (Feb 14, 2011)

2009 IBC

Several year old building, originally classified as Group M.  No idea if CO ever obtained, but doubtful since the drywall in this space has not been installed, and neither have the restroom fixtures.  The sanitary piping has been stubbed up through the floor in the rear of the building in the location of the originally proposed unisex restroom.

The use group is now being changed to a B for a "Pick-up / To-go" only food establishment.  No tables are provided for eating.

Is a public restroom required?  I've never seen restrooms available in these type of establishments, but that's not to say they aren't required.  Per the definition below, I would think that a restroom is required since the front 10 ft of the space is for food pick-up and therefore the building is intended for public utilization.

Thoughts?  Exceptions?

Thanks in advance!

*2902.3 Required public toilet facilities.* Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization. The number of plumbing fixtures located within the required toilet facilities shall be provided in accordance with Section 2902.1 for all users. Employees shall be provided with toilet facilities in all occupancies. Employee toilet facilities shall either be separate or combined employee and public toilet facilities.


----------



## fatboy (Feb 14, 2011)

Tough one. I've been plenty of places where the crowd waiting for food to go easily exceeds 15, and thus would require separate facilities. But, I would probably lean towards allowing the accessable unisex.


----------



## Mech (Feb 14, 2011)

I was actually trying to avoid providing one since the current building layout would require customers to walk through the food prep area to reach the restroom, which is a no-no.


----------



## fatboy (Feb 14, 2011)

One still has to be provided................


----------



## mark handler (Feb 14, 2011)

If the business has customers, patrons and visitors in their business then they must allow the public use of the toilet facilities in that space because they have public utilization, And It must be accessible.


----------



## Rick18071 (Feb 15, 2011)

Had a couple like this myself where they wanted to convert a house garage to a drive-up pick up. must have public rest rooms.


----------



## steveray (Feb 15, 2011)

Agree...must be provided.


----------



## Dr. J (Feb 15, 2011)

A toilet for all the people represented by the square footage of the Establishment is required by code.   Requiring the owner to open up that toilet for Any Joe Blow is not.

Just saying I agree a toilet is required, but the owner can limit who can use the toilet.


----------



## mark handler (Feb 15, 2011)

Dr. J said:
			
		

> A toilet for all the people represented by the square footage of the Establishment is required by code.   Requiring the owner to open up that toilet for Any Joe Blow is not. Just saying I agree a toilet is required, but the owner can limit who can use the toilet.


If the business has customers, patrons and visitors in their business then they must allow the public use of the toilet


----------



## north star (Feb 15, 2011)

** * * **



> "The business has customers, patrons and visitors in their business then they must allow the public use of the toilet.""


 The owner / manager could simply place a sign on the door saying "Out of Order",

or tell customers that the restroom is "Out of Order"......How many customers are

actually going to go check to ensure their ' code rights ' are being adhered to?

Just saying...

While the building code DOES require that an Accessible toilet be available to

John Q. Public, ...IMO, there should be some ability of the business owner to screen

useage.

EXAMPLE: A strip center with a tenant space used as a Mercantile occupancy.

Restroom is in the rear of the space......A young female working there all alone.

( as is commonly the case in smaller retail businesses )....Is her safety & security

more important that someone having to use that restroom?....Oh yeah, this is your

daughter working there.

** * * **


----------



## BSSTG (Feb 15, 2011)

Greetings

Here in Tx a restroom with hot water would be required per the health guys if I'm not mistaken. What I can't figure is where do folks go if they have a mobile taco or burger stand.

On restricting usage of the restroom. I've never seen in any code book that requires the restroom must be made available to the public. Lots of folks hang the "out of order" sign.

BS


----------



## mark handler (Feb 15, 2011)

BSSTG said:
			
		

> GreetingsHere in Tx a restroom with hot water would be required per the health guys if I'm not mistaken. What I can't figure is where do folks go if they have a mobile taco or burger stand.
> 
> On restricting usage of the restroom. I've never seen in any code book that requires the restroom must be made available to the public. Lots of folks hang the "out of order" sign.
> 
> BS


This is from the code:

If the business has customers, patrons and visitors *in* their business then they *shall allow the public use *of the toilet

Not the words in bold, mobile truck does not permit people "in"

"Shall" is in the code


----------



## mtlogcabin (Feb 15, 2011)

PUBLIC OR PUBLIC UTILIZATION. In the classification of plumbing fixtures, "public " applies to fixtures in general toilet rooms of schools, gymnasiums, hotels, airports, bus and railroad stations, public buildings, bars, public comfort stations, office buildings, stadiums, stores, restaurants and other installations where a number of fixtures are installed so that their utilization is similarly unrestricted.


----------



## mtlogcabin (Feb 15, 2011)

"This is from the code:

If the business has customers, patrons and visitors *in* their business then they *must allow the public use *of the toilet"

Not in the I-codes that I can find. What section number


----------



## mark handler (Feb 15, 2011)

mtlogcabin said:
			
		

> this is from the code:If the business has customers, patrons and visitors *in* their business then they *shall allow the public use *of the toilet not in the i-codes that i can find. What section number


Went off memory wording slightly different, but not the intent

ibc 2902.3

2902.4 Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.

The accessible route to public facilities shall not pass through kitchens, storage rooms, closets or similar spaces. Employees shall be provided with toilet facilities in all occupancies.

Employee toilet facilities shall be either separate or combined employee and public toilet facilities.

INTERNATIONAL BUILDING CODE® COMMENTARY

Public facilities are required in all spaces to be used by the public, including restaurants, nightclubs, places of public assembly and business occupancies open to the public. It is inappropriate to locate them in a storage area, behind the kitchen or in other areas not open and available to the public, primarily for the safety of the occupants that are from the general public. This provision avoids placing occupants from the general public in an unfamiliar area of the building where they could be confused about the path of egress in an emergency. The code requires employees to be provided with toilet facilities in all occupancies and this can be satisfied by separate employee facilities or shared employee/public facilities.

IPC 403.4 Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in

structures and tenant spaces intended for public utilization. The accessible route to public facilities shall not pass

through kitchens, storage rooms, closets or similar spaces.


----------



## Dr. J (Feb 16, 2011)

The words of the code hinge on “intended for public utilization”.  It is not the code official making that determination.  Code officials do not determine the use of a building or spaces.  If the owner intends a space to be used as an office it is not up to the code official to say it is really intended for flammable storage.  Similarly, if an owner does not intend a building or tenant space for public utilization, it is not up to the code official to say otherwise.



> INTERNATIONAL BUILDING CODE® COMMENTARYPublic facilities are required in all spaces to be used by the public, including restaurants, nightclubs, places of public assembly and business occupancies open to the public.


While the best I can usually say of the commentaries is that they are a waste of ink, and in many cases just make stuff up, this quote reinforces what is actually written in the code.  Business occupancies NOT open to the public do NOT require public restrooms.  Same for restaurants, nightclubs, and places of public assembly – not all are to be used by the public.  A nightclub with a big bouncer keeping out nerdy engineer types is clearly NOT open to the public.  A McDonalds off the interstate IS open to the public.  A municipal office building IS open to the public (all you AHJ’s let bums do a paper towel bath in your restrooms right?), an engineer’s office IS NOT open to the public. All of these are OWNER decisions, not AHJ decisions.

So, can a building owner hang a sign saying “No Public Restrooms – Customers only” - YES.  Can a building owner say to the AHJ “Even though the square footage of my space says I need 4 WC, I only want to put in 1 because there are only 4 employees that will use the restroom”? NO – all 4 must be installed to meet the SF based code mandated fixture count.  Can the AHJ require these to be directly off the front door – NO.



> PUBLIC OR PUBLIC UTILIZATION. In the classification of plumbing fixtures, "public" applies to fixtures … so that their utilization is similarly unrestricted


If the owner decides not to have “general toilet rooms”, or has restricted the use of the fixtures, they are obviously not “unrestricted”, and therefore by definition, not public.  This definition is for “the classification of fixtures”.  It is there only to determine when other sections of the code apply (tempered water at lavs, public vs private use factors for sizing, etc).  It is not a laundry list of places where public toilet rooms are required.


----------



## DwightB (Feb 18, 2011)

One popular drive-in restaurant (most installations have no inside dining) in this area has a public accessible toilet at the rear of the building, no problem to walk around and use it.  That puts it near other plumbing they have in the building.  Would this work with your plan?


----------



## Yankee (Feb 18, 2011)

Dr. J please give an example of a business that has no "Customers, patrons or visitors"?

Here is an example -- a jewelry store that requires someone to unlock the door to allow a customer inside. Yes, they don't have to allow someone in if that someone knocks on the door and asks to use the bathroom, but once they allow someone inside they have to allow use of the bathroom.

The bathroom has to be available to anyone that is permitted to enter the business


----------



## Dr. J (Feb 21, 2011)

> Here is an example -- a jewelry store that requires someone to unlock the door to allow a customer inside. Yes, they don't have to allow someone in if that someone knocks on the door and asks to use the bathroom, but once they allow someone inside they have to allow use of the bathroom.The bathroom has to be available to anyone that is permitted to enter the business


Agree 100%  Perfect example of an owner determining that his business is not _intended for public utilization_.  Yes, there needs to be plumbing fixtures for the occupant load of the tenant space, and customers make up a large part of that example's occupant load, therefore the toilets are indeed for the customer's use, but there is no requirement for a *public* toilet room.

Note that several posters seem to be saying that your example is illegal - the jewelry store owner MUST provide a public toilet room and let anybody who knocks on the door use their restroom.  That is what I am arguing against.


----------



## yuanyelss (Feb 22, 2011)

Requiring the owner to open up that toilet for Any Joe Blow is not.A toilet for all the people represented by the square footage of the Establishment is required by code.


----------



## hlfireinspector (Feb 22, 2011)

I am going to throw a curve in this one. Popular drive up fast food joint (starts with SO_ _ C) now has outside seating for eating not in your vechile. How can they not provide public restrooms?


----------



## Yankee (Feb 23, 2011)

Dr. J said:
			
		

> Agree 100%  Perfect example of an owner determining that his business is not _intended for public utilization_.  Yes, there needs to be plumbing fixtures for the occupant load of the tenant space, and customers make up a large part of that example's occupant load, therefore the toilets are indeed for the customer's use, but there is no requirement for a *public* toilet room.Note that several posters seem to be saying that your example is illegal - the jewelry store owner MUST provide a public toilet room and let anybody who knocks on the door use their restroom.  That is what I am arguing against.


You are getting stuck up on the word "public". Public is everyone in the store including the employees, as you would use it to determine benchmarks for having required egress in this building populated by THE PUBLIC.


----------



## JBI (Feb 23, 2011)

Dr. J, Generally love to read what you have to say, but every time this subject comes up you go off on this conspiratorial stuff that is waaaaaay out there. I have, for many years now, used a tax preparer (the one with the 'cubic' name). This 'B' occupancy is located on Main Street, USA. Customers are in and out all day long, hence facilities must be made available to them. Nowhere in the Code, and no one I've seen on this board advocates forcing this 'B' occupancy to provide that these facilities be made available to indigents seeking a 'sink bath'. Limiting the use to 'customers' and/or 'patrons' is perfectly acceptable.


----------



## jim baird (Feb 23, 2011)

"...an example of a business that has no "Customers, patrons or visitors..."

There is one here.  An "artisan sausage" maker, who has only four employees, markets online and delivers to customers, needs only one unisex restroom for use of employees.


----------



## fatboy (Feb 23, 2011)

I would agree with Jim's analysis.....


----------



## JBI (Feb 23, 2011)

The sausage maker is an F-1, possibly an S-2. The problems/issues arise with occupancies that are, generally speaking, 'open to the public'. Most factories and warehouses are not, so the rules are different for them. Most businesses are 'open to the public' at least to a limited extent, so the facilities must be made available to those with a reason to be there. (and NO, I don't consider 'I gotta GO' to be a reason to be there...)


----------



## Dr. J (Feb 23, 2011)

Sorry guys.  My prescription refill came in and I feel better now.

I suppose I was reading too much into Mark's responses (and remembering the "let anyone in" posters on the I Gotta Pee thread).  I do see that most people on this thread are using the word "Public" as "non-employee", rather than "unwashed masses".

And yes, I will admit to a bit of conspiratorial thinking that the the gubmint is trying to pry the bathroom key out of my cold dead hand (when bathroom keys are outlawed ...).

So, maybe a constructive response to the OP.  Yes a pub... er... "customers, patrons, visitors, and employee"  toilet is required (my eye  was twitching as I started to type "public").  And the non-employees need non-kitchen access.  Howabout a room with both an interior door for the employee and an exterior door for the pub... visitors?  Also, remember that even the employee toilet can't open into the kitchen.


----------



## fatboy (Feb 23, 2011)

Nice response Doc.......got a couple chuckles out of me.   :cowboy


----------



## north star (Feb 23, 2011)

** * * **

Dr. J.,

Ya gotta watch that "twitching eye" thingy.    



** * * **


----------



## mark handler (Mar 5, 2013)

hlfireinspector said:
			
		

> I am going to throw a curve in this one. Popular drive up fast food joint (starts with SO_ _ C) now has outside seating for eating not in your vechile. How can they not provide public restrooms?


INTERNATIONAL BUILDING CODE® COMMENTARY

Public facilities are required in all spaces to be used by the public, including restaurants, nightclubs, places of public assembly and business occupancies open to the public.

your outdoor dining area is a space


----------



## lunatick (Mar 5, 2013)

hlfireinspector said:
			
		

> I am going to throw a curvin this one. Popular drive up fast food joint (starts with SO_ _ C) now has outside seating for eating not in your vechile. How can they not provide public restrooms?


My memory, of thier prototype from 4 years ago is they do.

Is used by both.

Entry from exterior into a hallway that has a control entry point to the kitchen.

Issue here though is you have a standalone restaurant where you have patrons that are intending to be there 15-30 minutes eating and drinking ready to eat foods. Where places of that type sometimes have hot rod shows. Where you could possibly hangout for hours if you desired.

versus,

what the OP described as a Take and Bake place. Though I have been there for 15 minutes waiting on my za. But you are there for as short a time as it takes to get it and get going to bake someplace else.

Like wise I would not expect such facilitation at a leather repair shop.

Dry Cleaners, etc.

IMO, I do not expect there to be a restroom for the customer at this type of biz.

Whereas the other I would.

IMO, if the code required it, I think the code is wrong. How would I exempt it? This I would need to think about to achieve the intent.


----------



## mtlogcabin (Mar 5, 2013)

> How would I exempt it?


Once the business provides a place to eat, a parking space and a server to bring the food to your car or outdoor seating then in my opinion there is no way around the IBC requirement to provide restrooms for the use of the businesses customers.

Even footnote d requires you to include outdoor seating


----------



## lunatick (Mar 5, 2013)

Mech

what do you mean by pickup/to go?

"The use group is now being changed to a B for a "Pick-up / To-go" only food establishment.  No tables are provided for eating."

Is it served ready to eat or not?


----------



## Alias (Mar 6, 2013)

delete delete


----------



## MikeC (Mar 7, 2013)

I recently had this same argument with our Health Officer.  We have a restaurant which was formerly a cellular phone store.  The Health Officer recited the PA Food Code (the OP is from PA), which is also very grey.  It requires a sink be made available for the convenience of the customer and then requires a toilet in another section, but nowhere in the requirement for that toilet does it say anything about the convenience of the customer.  Considering that the customers needs are addressed with the sink, but not with the toilet, it leads me to believe that a customer use toilet is not required.  The Food Code then continues on to state that toilet(s) must be available per the PA UCC requirements, which adopts the standards of the 2009 IBC for this case.  It was an interesting discussion.  When it was over, the customers now have access to a unisex water closet / lavatory at the rear of the building after walking through a cooking area.  It will never be perfect.  Try to throw some common sense into the code when you can.


----------



## Mech (Mar 7, 2013)

The tenant is a pizza business with no seating or tables.  There is a kitchen, a restroom, and a small waiting area to pick up food orders.

I think we ended up narrowing the kitchen and installing a corridor so customers could travel to the restroom at the rear of the space without walking through the kitchen.  (And the restroom did not open into the kitchen.)


----------



## RonU (Mar 7, 2013)

California has a Uniform Retail Food Facilities Law. A similar law may apply to this case. Be sure to check for that.


----------



## mark handler (Mar 7, 2013)

RonU said:
			
		

> California has a Uniform Retail Food Facilities Law. A similar law may apply to this case. Be sure to check for that.


Welcome Ron

The CALIFORNIA RETAIL FOOD CODE, does not require restrooms, when provided it does have "some" requirements


----------



## RonU (Mar 7, 2013)

mark handler said:
			
		

> Welcome RonThe CALIFORNIA RETAIL FOOD CODE, does not require restrooms, when provided it does have "some" requirements


Thanks Mark....I've enjoyed learning from you.

Regarding the CRFC ....restaurants >20k sq.ft. & constructed between July 1, 84 & Jan 1, 04 - required to have 1 min. restroom; any new bldg constr. after Jan 1, 04 that has a restaurant with on-site food consumption or is >20k sq.ft. is reqd. to have restrooms for customers. Whether or not, if restrooms are provided for the public, they should met accessibility standards....a point that has pretty clearly been made.

Thanks again


----------



## mark handler (Mar 7, 2013)

RonU said:
			
		

> Thanks Mark....I've enjoyed learning from you.Regarding the CRFC ....restaurants >20k sq.ft. & constructed between July 1, 84 & Jan 1, 04 - required to have 1 min. restroom; any new bldg constr. after Jan 1, 04 that has a restaurant with on-site food consumption or is >20k sq.ft. is reqd. to have restrooms for customers. Whether or not, if restrooms are provided for the public, they should met accessibility standards....a point that has pretty clearly been made.
> 
> Thanks again


You are using an out of date CALIFORNIA RETAIL FOOD CODE

http://www.cdph.ca.gov/services/Documents/fdbRFC.pdf


----------



## RonU (Mar 7, 2013)

Thanks for the link


----------



## mark handler (Mar 7, 2013)

RonU said:
			
		

> Thanks for the link


No problem

Once again welcome.... keep posting


----------



## MikeC (Mar 9, 2013)

I am assuming the original question was in regard to a restaurant in PA.

Here is the section of the PA Food Code that applies:



> § 46.823. Numbers and capacities of plumbing facilities. (a)  Handwashing facilities for employees and consumers.
> 
> (1)  Except as specified in paragraphs (2) and (3), at least one handwashing sink—and a number of handwashing sinks necessary for their convenient use by employees in areas specified in §  46.824(a) (relating to location and placement of plumbing facilities)—shall be provided.
> 
> ...


Pennsylvania Food Code

As I stated in my previous post.  The code specifically states who the handwashing facilities are intended to be used by.  The toilet and urinal section doesn't, but you can also reasonably assume that the Department of Labor and Industry would require the number require by the PA UCC, which references the IBC.


----------



## mark handler (Mar 9, 2013)

MikeC said:
			
		

> but you can also reasonably assume


If you read the posts you can see that code professionals do not "REASONABLY ASSUME" anything.

No grey, black or white.

Stated, no thinking


----------



## Architect1281 (Mar 10, 2013)

If you say public toilets are not available yes they are required..

[P] 2902.3 Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.......(exception covered mall at tenant space)

If you tell me NO we dont provide them .. I rerach for fly and ask " Got a Mop"?? Facilites Provided quickly...


----------



## mark handler (Mar 10, 2013)

Architect1281 said:
			
		

> If you say public toilets are not available yes they are required.. [P] 2902.3 Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.......(exception covered mall at tenant space)
> 
> If you tell me NO we dont provide them .. I rerach for fly and ask " Got a Mop"?? Facilites Provided quickly...


Just a note, some states do not adopt the chapter29 of the IBC and rely on the plumbing code. And some states do not adopt the IPC but instead use the UPC....

Just to throw in a stone.....


----------



## kilitact (Mar 10, 2013)

Architect1281 said:
			
		

> If you say public toilets are not available yes they are required.. [P] 2902.3 Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.......(exception covered mall at tenant space)
> 
> If you tell me NO we dont provide them .. I rerach for fly and ask " Got a Mop"?? Facilites Provided quickly...


And some reach for the phone. In most states once you open that fly, the people with the blue or/and white coats come for you.


----------



## rgrace (Mar 11, 2013)

You could always look at the 2015 IPC and get some guidance from it .....

The following was "Approved as Submitted" at the Final Actions Hearings (specifically new exception 2):

403.3 (IBC [P] 2902.3) Required public toilet facilities. Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization. The number of plumbing fixtures located within the required toilet facilities shall be provided in accordance with Section 403 for all users. Employees shall be provided with toilet facilities in all occupancies. Employee toilet facilities shall be either separate or combined employee and public toilet facilities.

Exceptions: Public toilet facilities shall not be required in:

1. Open or enclosed parking garages. Toilet facilities shall not be required in parking garages where there are no parking attendants.

2. Structures and tenant spaces intended for quick transactions, including take out, pick up and drop off, having a public access area less than or equal to 300 square feet.


----------



## Jim B (Mar 12, 2013)

Dr. J said:
			
		

> Sorry guys.  My prescription refill came in and I feel better now.I suppose I was reading too much into Mark's responses (and remembering the "let anyone in" posters on the I Gotta Pee thread).  I do see that most people on this thread are using the word "Public" as "non-employee", rather than "unwashed masses".
> 
> And yes, I will admit to a bit of conspiratorial thinking that the the gubmint is trying to pry the bathroom key out of my cold dead hand (when bathroom keys are outlawed ...).
> 
> .


Dr J,

Bathroom keys are outlawed already, more than one operation to open the door and may required tight pinching, grasping or twisting of the wrist; so as long as your not tight grasping or twisting anything else


----------



## mtlogcabin (Mar 12, 2013)

Jim B said:
			
		

> Dr J, Bathroom keys are outlawed already, more than one operation to open the door and may required tight pinching, grasping or twisting of the wrist; so as long as your not tight grasping or twisting anything else


How about the dressing rooms that an employee has to unlock so you may enter. Keyed access is not "outlawed", there might be a conflict with other portions of the code as you mentioned but there are alternatives such as electronic access restriction.


----------



## mark handler (Mar 12, 2013)

mtlogcabin said:
			
		

> How about the dressing rooms that an employee has to unlock so you may enter. Keyed access is not "outlawed", there might be a conflict with other portions of the code as you mentioned but there are alternatives such as electronic access restriction.


Dressing and changing rooms shall be accessible and reasonable accommodations shall be made for employees, but employee areasare not the same as public restrooms, which is the thread content


----------



## mtlogcabin (Mar 12, 2013)

Mark

I was refering to the dressing rooms in a merchantile where an employee has to unlock the dressing room door to provide access. I have seen multi story office buildings where a reader card was needed for access to the restrooms.


----------



## Mech (Mar 12, 2013)

Some restroom doors in our office building have keypads requiring a code to unlock the doors.


----------



## Architect1281 (Mar 13, 2013)

Or as the inspecta when the owner of the store  / accomodation says it is not intendes for the public, should we make him enter the building Lock the dorr to entry and post a do not enter Public Prohibited sign?


----------



## mark handler (Mar 13, 2013)

employee  areas are not the same as public areas

This thread is about public toilets


----------



## mtlogcabin (Mar 13, 2013)

I agree "A" & "M" are public. I don't agree all "B's" are public


----------



## Rick18071 (Mar 15, 2013)

Inspected a camp where they they keep youths that have been in trouble. They where doing alterations, mostly to the rest rooms. Rest rooms are not labeled. Not accesable either. In fact nothing is accessable . There are all boys and only men employees. The code on separate sex rest rooms don't work to good here. I guess they will have to go to an appeals  board..


----------



## globe trekker (Mar 15, 2013)

Rick18071,

What's going to happen when a female relative (mom, aunt, sister, cousin) comes to pick up

the troubled youths and they have to go to the restroom, ..or a handicapped female relative?


----------



## mtlogcabin (Mar 15, 2013)

Rick18071 said:
			
		

> Inspected a camp where they they keep youths that have been in trouble. They where doing alterations, mostly to the rest rooms. Rest rooms are not labeled. Not accesable either. In fact nothing is accessable . There are all boys and only men employees. The code on separate sex rest rooms don't work to good here. I guess they will have to go to an appeals  board..


Or you can just use the code and make a determination

2902.1.1

Exception: The total occupant load shall not be required to be divided in half where approved statistical data indicate a distribution of the sexes of other than 50 percent of each sex.

Require at least one for female visitors and you should be compliant


----------

