# Accessible Bathroom questions



## TimNY (Feb 26, 2010)

We don't get a lot of commercial construction, so I am going to admit I don't know as much about this as i should.I've attached a pdf of a proposed new bathroom (all the walls depicted in the picture are new).  Drawn by me, but taken off a set of plans recently submitted.These are my thoughts, let me know if I'm right or wrong, or if I'm missing anything.1. 604.3.1 clearance around the toilet; 60" wide min, 56" deep min (can the door be located in this 56" depth?  I think yes)2  IBC 1109.2.1.6 clear area.  This is in ANSi A117.1 somewhere as well?3. Front approach to the sink looks goodNow.. questions..If the door were changed to swing out, anything I should be looking at other than the means of egress requirements?Anything else I am missing on this layout?Taking the whole bathroom out of the scenario and just looking at this door.  It appears to me that if you actually did bring a wheelchair in there, you couldn't close the door.  Would this be a "hinge approach - pull side" scenario?Thanks,Timaccessible_bath.gif[/attachment:1bjy5npy]

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## jar546 (Feb 26, 2010)

Re: Accessible Bathroom questions

Are you both ADAAG and ANSI 117.1?  There are more restrictive requirements in ANSI 117.1.

This setup does not look close at all due to the space around the water closet and not enough information on latch side space.  There are more questions than answers on this one.


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## Gene Boecker (Feb 26, 2010)

Re: Accessible Bathroom questions



			
				TimNY said:
			
		

> These are my thoughts, let me know if I'm right or wrong, or if I'm missing anything.
> 
> 1. 604.3.1 clearance around the toilet; 60" wide min, 56" deep min (can the door be located in this 56" depth?  I think yes)
> 
> ...


Tim,

I'm guessing that this is a commercial application and not a bathroom inside a residence.  Those rules are slightly different.  That being said:

It looks like the turning circle overlaps the door while in the closed position.  That would be problematic.  The space under the sink "can" be used for turning if there is adequate knee space at the location where the turning occurs.  It looks like that would be the case.

There must be at least one 30x48 wheelchair space inside the room, beyond the arc of the door.  So, you're right, you couldn't close the door once you're in the room.

The hallway outside the room is only 38 inches wide.  To make an approach where a person woudl enter the room as shown (latch side, push) the width must be at least 42 inches.  If you shoudl decide to reverse the swing of the door, that woudl only make things worse.  Then the hallway woudl need to be at least 48 inches wide.

Other items include the fact taht a 42 inch grab rail on the side cannot be located on a 42 inch long wall.  The end of the grab bar is supposed to be 54 inches from the rear wall.  Also, the clear floor space for the water closet needs to be 60 inches wide from side wall to nearest object on the other side.

The space is simply too small.


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## RJJ (Feb 26, 2010)

Re: Accessible Bathroom questions

Agree! Needs major revision! NEC " Not even close"  :roll:


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## TimNY (Feb 26, 2010)

Re: Accessible Bathroom questions

jar: This is indeed a commercial bathroom, governed under IBC[or the NYS derivitive] and it's referenced standards (A117.1).

Gene: thanks so much for confirming what I thought.  Not sure which way he is going to go on this (the only way the toilet clearance can get bigger is by expanding into the hallway), but the door will either have to swing out (further reducing the hallway) or make the room longer so the 30x48 outside the arc of the door is there.

Thanks again,

Tim


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## Gene Boecker (Feb 26, 2010)

Re: Accessible Bathroom questions

I guess one question that I didn't ask is if this is new construction or renovation of existing.  In new construction, there's no option but to fully comply.  With existing construction there is the 20% rule and some leniency.  Good luck.


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## brudgers (Feb 26, 2010)

Re: Accessible Bathroom questions

It's not even close.

Door can't swing across the clear floor area for any fixture (though it can swing across the circle all day long).

If that sink has cabinets under it, it's inaccessible.

the sink and lav. cannot intrude into the top of the clear floor area for the toilet.

needs grab bars.

Etc.


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## Jasper (Feb 26, 2010)

Re: Accessible Bathroom questions

A pocket door might help.

Here is a link to a case study of a similar design problem:

http://www.beforethearchitect.com/P&E-CS11.htm

http://www.johnsonhardware.com/images/pdf/handicap_acc.pdf


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## Plans Approver (Feb 27, 2010)

Re: Accessible Bathroom questions

Ditto to what everyone else said. Also, the hallway is too narrow see A117.1, 404.2.3 (and ADAAG 4.13.6).


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## Inspector Gift (Feb 27, 2010)

Re: Accessible Bathroom questions

Try looking at the great "Accessiblity Toilet Room" examples at the SW Washington ICC Chapter website.

TimNY, I think you will find some good solutions for the applicant to use.


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## TimNY (Mar 1, 2010)

Re: Accessible Bathroom questions

Thank you for all the replies.

This is new construction in an existing shell space.  It's wide open now, but they are dividing it up into offices and adding this bathroom.

brudgers thanks for that info, that's the kind of stuff I am not familiar with.  I knew the door could swing into the circle, but was ignorant of it being precluded from swinging across the clear area.

Grab bars, insulated piping under the sink etc, I am familiar with.  Thanks.

Tim


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## Tom_Fallon (Mar 11, 2010)

Re: Accessible Bathroom questions

I would highly recommend you hire a local architect familiar with commercial projects to consult or subcontract.  I know I am probably late, but if you do not have experience with ADA and your local commercial code you are opening yourself, your client, and the owner/tenant up to a ton of liability issues.  Accessibility varies by state/jurisdiction as well and may have additional requirements in addition to ADA.  Some jurisdictions do not allow the door to swing into the turning radius at all and some put a 12" limit on that swing infringement.  As pointed out by many other people, the hallway is too narrow, the door cannot swing into the clear space for any fixture and there are many other issues.  You need to read all the applicable code sections of your state/local building code and ADA and even then you should get a local expert's review (architect).  Relying on comments from a forum such as this will not constitute a proper consultation in a court of law in my opinion (although I am no expert in law!).  If you manage to get your plan or some variation of it approved by the plans examiner and the building inspector, that will  not release you or anyone involved in the project from any liability.


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## Tom_Fallon (Mar 11, 2010)

Re: Accessible Bathroom questions

(erased this explanation as I modified my previous post)


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## TimNY (Mar 12, 2010)

Re: Accessible Bathroom questions



			
				Tom_Fallon said:
			
		

> I would highly recommend you hire a local a-r-c-h-i-t-e-c-t (sorry for the hyphenation but when I submit this word, it gets changed to 'man with pencil who draw') familiar with commercial projects to consult or subcontract.  I know I am probably late, but if you do not have experience with ADA and your local commercial code you are opening yourself, your client, and the owner/tenant up to a ton of liability issues.  Accessibility varies by state/jurisdiction as well and may have additional requirements in addition to ADA.  Some jurisdictions do not allow the door to swing into the turning radius at all and some put a 12" limit on that swing infringement.  As pointed out by many other people, the hallway is too narrow, the door cannot swing into the clear space for any fixture and there are many other issues.  You need to read all the applicable code sections of your state/local building code and ADA and even then you should get a local expert's review (a-r-c-h-i-t-e-c-t).  Relying on comments from a forum such as this will not constitute a proper consultation in a court of law in my opinion (although I am no expert in law!).  If you manage to get your plan or some variation of it approved by the plans examiner and the building inspector, that will  not release you or anyone involved in the project from any liability.


Thanks Tom.

I am the AHJ.  This was submitted by a registered architect.  I will forward your message to him  

(I re-drew his drawing to avoid any copyright issues)

Tim


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## Examiner (Mar 12, 2010)

Re: Accessible Bathroom questions

I got on this late but the response about the visable plan issues are good.  I think the Architect should learn his trade.  I am an Architect and I can pretty much assure you that this guy did not review the work or he does not know accessibility like he should.

Bascially the restroom is too small and the accessible route is too narrow.  What about separate restrooms?  Is the occupant load over 15?  Accessiblity would require accessible separate facilities if the Plumbing Code requires separate facilities.  And the law suits keep coming.


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## TimNY (Mar 15, 2010)

Re: Accessible Bathroom questions

As somebody which is not as familiar with accessibility as I should be, you can understand my hesitation when reviewing plans like this.

It's not even close, which makes me second-guess if I am correct.  It's great having this board to bounce issues off of you guys.

I spent about an hour on the phone with him, and I believe all of the issues will be corrected on the next submittal.  Even though I noted all the code sections on the review, there was some question on interpretation.

Accessibility was just one issue.  Doors swinging completely into the means of egress, receptacles and data outlets proposed in shaftwalls, lack of sprinkler plans were some of the others.

He seems genuinely interested in doing the right thing, but I don't think he should be coming to me for his education.  However, I do provide service with a smile  

Tim


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## JBI (Mar 15, 2010)

Re: Accessible Bathroom questions

Tim - Surely you've met Joe Reich from the NYS (Disability) Advocates office? He's our 'go-to' guy here in NYS for all things Accessible. Look him up on the state website or get his number from your Regional Office, it is invaluable. If you haven't taken the Accessibility class yet, you should. It's an excellent course and full of great information.

For the record, I agree with most of the replies you've received. The tricky part is remembering that ADA/ADAAG are NOT yours to enforce, Chapter 11 and Ansi ARE. The Architect needs to comply with all 3 in his design. You only review to the Code and the Standard.


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## TimNY (Mar 15, 2010)

Re: Accessible Bathroom questions



			
				John Drobysh said:
			
		

> Tim - Surely you've met Joe Reich from the NYS (Disability) Advocates office? He's our 'go-to' guy here in NYS for all things Accessible. Look him up on the state website or get his number from your Regional Office, it is invaluable. If you haven't taken the Accessibility class yet, you should. It's an excellent course and full of great information. For the record, I agree with most of the replies you've received. The tricky part is remembering that ADA/ADAAG are NOT yours to enforce, Chapter 11 and Ansi ARE. The Architect needs to comply with all 3 in his design. You only review to the Code and the Standard.


I'm not sure if Ive dealt with him before.  I did have a difference of opinion with somebody up there regarding required height for garage doors.  Something to do with where parking is provided inside and outside, there should be accessible parking provided inside.  I said the door height (vertical clearance) needed to comply for the indoor parking that was to be accessible, they said no.  It blew my socks off.  As with most interpretations, nobody will provide anything in writing.  In the end I told the arch we can fight about it for months or you can comply and get your permit in a few weeks.

None the less, I wouldn't bother him with such a trivial problem, this was more of just needing some reassurance.  I had most of the sections, just wondering if I was nuts, or was a RA submitting something completely non-compliant.

I am only referencing CH11 and ANSI A117.1.  I have the ADA guidelines here, and I mention them when speaking to people (we did have a Federal suit brought against one of the retail stores here), but definitely don't cite from them.

As for the accessibility course, I would love to take it.  Unfortunately we don't get much diversity down here.  As we were told in class "the State requires you do have 24 hours, the State is not required to provide it to you".  I've taken many course twice just to get the hours.  I took the online course accessibility for small governments (I think that's what it was called), which was pretty good but related more to making public facilities accessible.

Thanks again,

Tim


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## JBI (Mar 15, 2010)

Re: Accessible Bathroom questions

Tim, you'd remember Joe... he's wheelchair bound. Nice guy and sharp as they come on accessibility.

Formal interpretations are always in writing, maybe you were getting 'opinions'?

Codes Division (I think it was them...) used to publish a comparative analysis of the 'big three' (Chap 11, ANSI & ADA/ADAAG). It used to give me headaches trying to follow it, but it had all the major issues side by side for comparison.


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## TimNY (Mar 16, 2010)

Round 2Trying to use the exceptions in 1109.2, the office has grown to encompass the bathroom now.  :rollage0001.gif[/attachment:3otunggi]

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## Big Mac (Mar 16, 2010)

Re: Accessible Bathroom questions

The doors are still required to have a 32” clear opening.

Clear floor space requirements within the toilet room at fixtures must still be met.

The only portions of the toilet room design that do not need to be met are encompassed in exception #1.  If a design change is not authorized in that section, it cannot be made.

This toilet room must be for the use of the person that occupies the office it is in, and no other.

This toilet room cannot be counted toward satisfying the number of fixture

The intent is that this room can be made fully accessible if they change the toilet, install grab bars, remove the cabinetry from below the sink and reverse the door swing.  It appears to me that they still have work to do


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## TimNY (Mar 16, 2010)

Re: Accessible Bathroom questions

Originally they "had" to have this bathroom because of the people they would be counseling, rather than just using the ones in the hallway (very close).  Now, I agree, they should have a private bathroom for the use of the clients given the use of the space; it is a very good idea.

Now all of a sudden this is supposed to be a private bathroom.  Heck, you could go out the door at the top walk about 10 feet and be in the hallway bathrooms.  I am not going to try and prove it is for the use of more than one person, it's their lawsuit.  It just amazes me the length people will go to in order to discriminate against the disabled.  Probably not their intent, but come on let's use our brains a little bit.

The guy just doesn't get it.  I wasted so much time on the phone trying to work this out.  Then out of the blue we have this new idea on how to comply.

This one is going to sit on the desk for a while, I tried my best to help and this is just ridiculous.

Build an accessible bathroom first, then take your exceptions.  The requirements are pretty darn clear in the code (heck, if I can understand them, they must be!)


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