# clear floor space at toilet part of circulation path?



## syarn (Jul 10, 2012)

is the clear floor space at a toilet has an electric hand dryer over lapping it a bit AND the hand dryer projects more than 4" off the wall within the toilet clear floor space is this a violation because the toilet clear floor space is considered part of the circulation path?


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## syarn (Jul 10, 2012)

actually also including the clear floor space at a sink....is that considered part of the circulation path?


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## Examiner (Jul 10, 2012)

The hand dryer is a protruding object since it occurs in the circulation path and projects more than 4".  The sink cannot project into the require floor space of the accessible water closet, basically a 5'-sq floor space for the water closet must be free of the lav.  Graphics in both ADA and the ANSI A117.1 are pretty clear on this.  They do make new ADA compliant hand dryers now.  However, its location should not be in the area of the accessible water closet.


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## daniel45 (Mar 11, 2017)

syarn said:


> is the clear floor space at a best toilets for small spaces has an electric hand dryer over lapping it a bit AND the hand dryer projects more than 4" off the wall within the toilet clear floor space is this a violation because the toilet clear floor space is considered part of the circulation path?



Hello,
Clearances are required at accessible elements, fixtures, and controls so that people with disabilities, including those who use wheelchairs, can approach and use them. The standards also address maneuvering space for wheelchair turning.


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## mark handler (Mar 11, 2017)

syarn said:


> is the clear floor space at a toilet has an electric hand dryer over lapping it a bit AND the hand dryer projects more than 4" off the wall within the toilet clear floor space is this a violation because the toilet clear floor space is considered part of the circulation path?


Which Code? Year?


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## steveray (Mar 13, 2017)

2009 ANSI 117

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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## ADAguy (Mar 14, 2017)

Same language in ADASAD?


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## Yikes (Mar 14, 2017)

Same language is in CBC 604.3.2 and ADAS.

steveray, I find it interesting that if I wanted to dry my hands using paper towels, I could have a "paper dispenser" overlap the toilet clearance (notice that 604.3.2 didn't say what _kind_ of paper it is supposed to dispense: toilet paper, kleenex, a** gaskets, or paper towels); but if I want a power dryer of the exact same size as the paper dispenser, that is not allowed because it says "no other obstructions".

Here's some other oddities:

The flexible water supply line and shutoff valve on the rear wall of the toilet are "other obstructions" technically not allowed, because the required toilet clearance goes all the way to the wall surface behind the toilet
A sanitary napkin dispenser is not allowed, but a sanitary napkin receptacle is allowed.
A giant 4" deep shelf such as a diaper changing table is allowed, but a vanity of identical size with a 4" deep sink bowl would not be allowed (except in ADA residential dwelling units).


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## Rick18071 (Mar 15, 2017)

Where does it say a diaper changing table is allowed? It would come out more than 4" if left open.


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## steveray (Mar 15, 2017)

IF.....If someone left a dead body in there it would be a violation too.....Or you could just make sure that the changing table was within the accessible reach ranges and operable and they could get it out of their own way.


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## steveray (Mar 15, 2017)

Yikes said:


> Same language is in CBC 604.3.2 and ADAS.
> 
> steveray, I find it interesting that if I wanted to dry my hands using paper towels, I could have a "paper dispenser" overlap the toilet clearance (notice that 604.3.2 didn't say what _kind_ of paper it is supposed to dispense: toilet paper, kleenex, a** gaskets, or paper towels); but if I want a power dryer of the exact same size as the paper dispenser, that is not allowed because it says "no other obstructions".



Correct....I didn't want to bring that up, but yes, even though I don't agree I would lose that argument unless commentary speaks of it or a newer version of ANSI.

By that poor code language I could have a 3000# roll of paper that dispenses into a printing press in there..


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## Yikes (Mar 15, 2017)

Rick18071 said:


> Where does it say a diaper changing table is allowed? It would come out more than 4" if left open.


CBC 604.3.2, ADAS, and ANSI all allow "shelves" to encroach into the toilet clearance, with no limitation (_4", or 44"!_) on the amount of encroachment.
A diaper changing table is a type of "shelf" for babies, and other purposes, so it is allowed.


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## Paul Sweet (Mar 17, 2017)

Poor code language is job security for lawyers.


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## Rick18071 (Apr 4, 2017)

CIRCULATION PATH. An exterior or interior way of passage from one place to another for pedestrians.

So why isn't the area next to the toilet part of a circulation path?  It's used to get from the toilet to the sink or wheel chair. If that is the case the sink could be a protruding object besides a more than 4" deep shelf.


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