# Paper Towel Dispenser in WC Clear Space?



## Mech (Jan 22, 2018)

ANSI A117.1 - 2009

Section 604.3.3 Clearance Overlap.  The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, paper dispensers, sanitary napkin receptacles, coat hooks, shelves, accessible routes, clear floor space at other fixtures and the turning space.  No other fixtures or obstructions shall be with the required water closet clearance.

Does the section above allow paper towel dispensers or only toilet paper dispensers?

I have always kept my designs to toilet paper only.


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## classicT (Jan 22, 2018)

"Paper dispensers"

I'd include paper towel dispensers in the exception, however am not sure how one would mount one where it did not interfere with the grab bars.

Any example floor plans?


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## Pcinspector1 (Jan 22, 2018)

I would say that the paper towel dispenser is outside of the toilet area. I have not seen a universal ADA drawing with paper towels inside the toilet area.

But I believe the "paper cowboy hats" are allowed inside the toilet area.


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## ADAguy (Jan 22, 2018)

consider a paper towel dispenser mounted on the rear wall between the WC & the side of the Lav, that projects more than 4" but the height of its  dispensing opening is less than 40" but higher than 27" ?


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## steveray (Jan 23, 2018)

I don't like it, but have allowed it...


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## north star (Jan 23, 2018)

*@ ~  @ ~ @*

PC,

What does a paper cowboy hat look like ?

*@ ~ @ ~ @*


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## Pcinspector1 (Jan 23, 2018)

Paper cowboy hats, usually behind and above the toilet


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## mark handler (Jan 23, 2018)

Pcinspector1 said:


> Paper cowboy hats, usually behind and above the toilet


Above usually presents a reach problem.


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## ADAguy (Jan 23, 2018)

On the wide side of the WC on the rear wall below the grab bar is best.


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## Francis Vineyard (Jan 23, 2018)

Isn't 604.3.3 applicable to all the elements listed permitted to have their clear floor space to overlap in accordance with the following provisions?
*
operable part:* A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust the element.
*
301.2 Overlap.* Unless otherwise specified, clear floor spaces, clearances at fixtures, maneuvering clearances at doors, and turning spaces shall be permitted to overlap.
*
309 Operable Parts

309.1 General. *Operable parts required to be accessible shall comply with Section 309.
*
309.2 Clear Floor Space. *A clear floor space complying with Section 305 shall be provided.

For the toilet paper dispenser to fall within the reach range while disposed, the applicable sections would be 604.7 & 604.11.7
*
604.7 Dispensers.* Toilet paper dispensers shall comply with Section 309.4. Where the dispenser is located above the grab bar, the outlet of the dispenser shall be located within an area 24 inches minimum and 36 inches maximum from the rear wall. Where the dispenser is located below the grab bar, the outlet of the dispenser shall be located within an area 24 inches minimum and 42 inches maximum from the rear wall. The outlet of the dispenser shall be located 18 inches minimum and 48 inches maximum above the floor. Dispensers shall comply with Section 609.3. Dispensers shall not be of a type that control delivery, or do not allow continuous paper flow.


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## Pcinspector1 (Jan 23, 2018)

So Francis, a roll of toilet paper cannot be on the toilet tank lid, what about the can of deodorant spray, I suppose that can't be on the lid either...Nuts!



Mech said:


> Does the section above allow *paper towel dispensers* or only toilet paper dispensers?



Would't want paper towels (Brawny) going down the loo!


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## Yikes (Jan 23, 2018)

Pcinspector1 said:


> So Francis, a roll of toilet paper cannot be on the toilet tank lid, what about the can of deodorant spray, I suppose that can't be on the lid either...Nuts!



"Shelves" are an allowed component.  BTW, that includes a baby changing table.
The code is silent-but-deadly (couldn't resist!) on the subject of deodorant cans or whatever else gets to sit on the shelf.
Likewise, it allows coat hooks, but is silent on the coats themselves.
I presume that means this portion of the code is concerned primarily about permanently affixed components.


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## tmurray (Jan 23, 2018)

Pcinspector1 said:


> Paper cowboy hats, usually behind and above the toilet


I heard of a study recently that found more bacteria on the toilet seat covers than on the toilet seats themselves. Toilet seats are designed and constructed out of material that restricts bacteria. Paper on the other hand, is great at trapping and giving them food to grow.


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## ADAguy (Jan 23, 2018)

"Yummy" !


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## Rick18071 (Jan 24, 2018)

But can you allow a bookcase, sanitary napkin receptacle on the floor or self supporting toilet paper holder next to the WC? The code doesn't seem to require if this stuff is mounted on the wall or not.


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## Francis Vineyard (Jan 24, 2018)

Commentary; "It is not the intent of this section to prohibit these items within the toilet room or stall, but rather to make sure that these items are located so that they do not block access to the water closet within the room or stall."

Also refer to section 609.3 for clearances above a below grab bars.


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## ADAguy (Jan 24, 2018)

Do they interfere with the clear floor space for a WC? They might be located between the WC and a wall but could then be hard to use.
Given that they are not "fixed elements" they might be seen as "maintaince " items similar to trash receptacles that obstruct mobility.


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## Rick18071 (Jan 24, 2018)

Francis Vineyard said:


> Also refer to section 609.3 for clearances above a below grab bars.



These items that I mentioned would not be above or below the grab bar but in front of it.



ADAguy said:


> Given that they are not "fixed elements" they might be seen as "maintaince " items similar to trash receptacles that obstruct mobility



But what if they were fixed, it looks like the code would allow it.


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## ADAguy (Jan 24, 2018)

"Fixed" as in a corner as decoration or functional elements?


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## Rick18071 (Jan 25, 2018)

I mean the code seems to be ok with a bolted down (fixed) bookcase (shelving), sanitary napkin receptacle or self supporting toilet paper holder anywhere in the required WC clear space as long it complies with section 609.3 for clearances above a below grab bars. I'm thinking that they could away from the walls and in the middle of the required clear space.


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## ADAguy (Jan 25, 2018)

In the middle?!


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## mark handler (Jan 25, 2018)

ADAguy post: 177130 said:
			
		

> In the middle?!


In the middle Is not clear


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## Rick18071 (Jan 25, 2018)

Ok let's say 30" from open side of WC and 30" from the wall that is behind the WC is a self supporting toilet paper dispenser or a self supporting shelf attached to the floor. It looks like the code is ok with this.The code does not say that the shelf or anything else that it allows per section 604.3.2 in this space needs to be on the wall.


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## ADAguy (Jan 25, 2018)

If attached to the floor how far does it project out from the face of the wall? Appears to be an obstruction.


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## HForester (Jan 26, 2018)

Pcinspector1 said:


> what about the can of deodorant spray, I suppose that can't be on the lid either...Nuts!
> 
> The controls on the can would have to comply with ADA controls requirements........HAH !


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## ADAguy (Jan 26, 2018)

Not if you install a Toto, ever try one? "Whoopee"!


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## Rick18071 (Jan 26, 2018)

ADAguy said:


> If attached to the floor how far does it project out from the face of the wall? Appears to be an obstruction.



It doesn't matter how far from the wall. It looks to me that the items in section 604.3.2 could be anywhere in the required WC clearance.


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## ADAguy (Jan 26, 2018)

If in the clear floor area, then how could it not be a barrier? Maybe if he posted a floor plan?


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## Rick18071 (May 18, 2018)

What I am talking about is that there is a shelving unit that is 36" long against the wall and comes out 30" from the wall, is 6' high, 5 shelfs, lowest shelf is 3" from the floor. I am sure many of you have this type of shelf unit in your garages or basements. It is between the toilet and the sink. They are keeping supplies for the toilet room on it.


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## ADAguy (May 18, 2018)

30"! it extends beyond the face of the lav? and obstructs access to the toilet lever.


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## Rick18071 (May 21, 2018)

Toilet has a automatic flusher. The problem is the code allows shelving in the water closet clear space but has no limit in how large or where it is. They could even put shelving between the toilet and wall. When I fail inspection I am required to state a code section and there is nothing I can use for this.


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## my250r11 (May 21, 2018)

Have to slouch to use it? Picture would be helpful. Even if automatic it still has the push button that needs to be accessible.


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## mark handler (May 22, 2018)

Rick18071 said:


> Toilet has a automatic flusher. The problem is the code allows shelving in the water closet clear space but has no limit in how large or where it is. They could even put shelving between the toilet and wall. When I fail inspection I am required to state a code section and there is nothing I can use for this.


ICC A117.1
604.3.3 Clearance Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, paper dispensers, sanitary napkin receptacles, coat hooks, *shelves,* accessible routes, clear floor space at other fixtures and the turning space.
No other fixtures or obstructions shall be within the required water closet clearance


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## Rick18071 (May 22, 2018)

mark handler said:


> ICC A117.1
> 604.3.3 Clearance Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, paper dispensers, sanitary napkin receptacles, coat hooks, *shelves,* accessible routes, clear floor space at other fixtures and the turning space.
> No other fixtures or obstructions shall be within the required water closet clearance



That is what I am saying. There is no limit on how much the shelves take up of if they need to be mounted to the wall.


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## mark handler (May 22, 2018)

Rick18071 said:


> That is what I am saying. There is no limit on how much the shelves take up of if they need to be mounted to the wall.


I posted that because Rick18071 needed a cite number to use.


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## Paul Sweet (May 23, 2018)

Would 609.3 (projecting objects above & below grab bars) help?  The rear grab bar is supposed to extend beyond the edge of the toilet (604.5.2).


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## Rick18071 (May 23, 2018)

This shelf unit has a supports on all 4 corners so it has no projections and it is not above or below the rear grab bar, it's in front of it.


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## Paul Sweet (May 24, 2018)

If it blocks part of the grab bar then it's an obstruction and an ADA violation.


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## mark handler (May 25, 2018)

...in front of it?
???


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## Rick18071 (May 25, 2018)

I don't enforce ADA only the ICC codes  allows shelfs in the water closet clearance and there is nothing that says shelfs can't be in front of the grab bars.


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