# Toilet paper dispensers



## Rick18071 (May 3, 2019)

There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.

So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?


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## JPohling (May 3, 2019)

it also has a requirement for distance from the front of the bowl


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## RLGA (May 3, 2019)

Dispensers are required to also comply with ADA Section 604.7, which addresses the location requirements in general.


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## ADAguy (May 3, 2019)

Rick18071 said:


> There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.
> 
> So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?



Love your PA questions


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## Rick18071 (May 6, 2019)

JPohling said:


> it also has a requirement for distance from the front of the bowl



This was true in the ICC/ANSI 117.1 2003 but not in the 2009 that I am using now. The code requires the toilet paper dispenser to be a certain distance from the rear wall only if it is mounted above or below the grab bar:

604.7 Toilet dispensers shall comply with section 309.4. Where the dispenser is located above the grab bar, the outlet of the dispenser shall be located withing 24" min. and 36" max. 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" min. and 42" max. from the rear wall. The outlet of the dispenser shall be located 18" min. and 48" max. above the floor. Dispensers shall not be the type that control delivery, or do not allow continuous paper flow.



RLGA said:


> Dispensers are required to also comply with ADA Section 604.7, which addresses the location requirements in general.



Interesting but don't enforce ADA and don't care or know it.


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## Builder Bob (May 6, 2019)

Rick - Partially correct - this has been somewhat cleared up in the 2017 version of the ICC ANSI A117.1, the distance requirement to the front of bowl is applicable when a double roll toilet paper dispenser is used - see exception to 604.7.1


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## ADAguy (May 6, 2019)

Rick, are you an architect, inspector or .... ? 
Makes no difference, contrary to the code, your state laws must at a minimum be equal to but no less than the 2010 ADASAD.
As to wall side mounted vs the open side, if mtd. on the open side it would exceed reach ranges, if post mtd. it would obstruct floor space.
What is the reason for the initial question?


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## Yikes (May 8, 2019)

Rick18071 said:


> There does not seem to be a requirement that a Toilet paper dispensers to be on the wall next to the toilet. The code only specifies where it should be if it is over or under the grab bar and the height of it no matter where it is.
> 
> So does that mean it could be anywhere in the room including on the open side wall or self standing dispenser as long it is 18 to 48 inches above the floor?



Rick, there was a similar discussion in another thread - - this seems like a weird loophole, but I think you are correct.  ADAS and the code only seem to address 2 of the 3 dimensions for T.P. dispensers: vertical height above finish floor, and horizontal distance in front of the bowl rim.  It does not address the side-to-side distance from the centerline of the toilet; probably most everyone assumes you intend to mount it on the closest side wall.

However, ADAS  604.3.2 allows dispensers and many other components to "overlap" the required maneuvering clearance around the accessible toilet:  
_604.3.2 Overlap.  The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. _​No other fixtures or obstructions shall be located within the required water closet clearance.

In theory, you could have a T.P. floor stand centered 7" directly in front of the rim, making transfer from a wheelchair impossible, and yet it would still comply with the letter-of-the-law.






Furthermore, ADAS 604.3.2 doesn't limit the purpose of the "dispenser".  Again, in theory, it could be a soda vending machine, dispensing cans of coke: it's a "dispenser", allowed to encroach.

Lastly, I don't think there is anything in the building or plumbing codes that compel either the toilet paper or the toilet paper dispenser to be provided at all!  Bring your own corn husk.


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## ADAguy (May 9, 2019)

Talk about opening a bag of worms? Placing it on the wide side would not be defensible as it also does not meet any measurable standard of practice.
Show me a standard of practice reference where you have seen it located otherwise.


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## Yikes (May 9, 2019)

ADAguy, I appreciate the concern for standard of practice.  But the original post wasn't about standard of practice, it was about the "requirement" of what the "code only specifies".  
In this case, the code - as written - allows for a design where you meet the letter of the law, but not the spirit of its intent (a usable toilet for persons with disabilities).

My larger point about "loopholes" is probably the same as what I think you're saying - that code alone is insufficient to create a truly usable building.  The minimum requirements of the code alone can only identify the legal boundary beyond which is "not compliant"; it can't force the central goal of what is the most appropriate design solution.  

Nevertheless, the original question was focused on what the code actually allows, not on what was the appropriate design standard of practice to meet the spirit of the code.


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## JPohling (May 9, 2019)

May be an instance where the code language does not specifically require the location but surely Ice would never allow that as well as any other inspector I could imagine.  A request for code language to support the inspectors requirement that the TP dispenser be relocated would fall on deaf ears and the GC would relocate.


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## Yikes (May 9, 2019)

JPohling, of course we are merely playing out a hypothetical here, and most GC's would pick and choose their battles with an inspector over something less mundane than a TP roll.
But remember, the building code does not require ANY toilet paper, nor a toilet paper dispenser.

Marginally-related story: In yesterday's NY Times, there was an article about the disappearing job of bathroom attendants.  There was a time when many toilets were pay toilets, and many the "dispensers" of toilet room consumables (towels, soaps, etc.) were live attendants.
https://www.nytimes.com/2019/05/08/style/bathroom-attendants.html

Also, some toilets these days come with built-in washlets (bidets) and dryers, claiming to make TP obsolete.
Point is, the code has always allowed for scenarios where there would be no toilet paper, or paper towels, or dryers.  So if the toilet paper floor rack shown in the earlier post was removed from the room during your inspection, what would be your legal mechanism to deny approval of the construction?  Yes, as an inspector you could make their life miserable in other ways, and you could delay them with deaf ears as long as possible, but it doesn't change what the code says or allows.


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## ADAguy (May 10, 2019)

The key code wording with regards to your question is : "If provided". If you do, your comment may be seen as valid as the dispenser could then be hung from a sky hook on the wide side as long as it met the 7- 9" and the reach ranges. Try to imagine that?


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## mark handler (May 10, 2019)

CA has Shall, not "If Provided".
You shall provide them.


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## mark handler (May 10, 2019)

Yikes said:


> Rick, there was a similar discussion in another thread - - this seems like a weird loophole, but I think you are correct.  ADAS and the code only seem to address 2 of the 3 dimensions for T.P. dispensers: vertical height above finish floor, and horizontal distance in front of the bowl rim.  It does not address the side-to-side distance from the centerline of the toilet; probably most everyone assumes you intend to mount it on the closest side wall.
> 
> However, ADAS  604.3.2 allows dispensers and many other components to "overlap" the required maneuvering clearance around the accessible toilet:
> _604.3.2 Overlap.  The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. _​No other fixtures or obstructions shall be located within the required water closet clearance.
> ...


*Interferes with clear space?*


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## ADAguy (May 10, 2019)

My point exactly


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## Yikes (May 10, 2019)

mark handler:  "Interferes with clear space?"
Quoting the code, which uses the term "overlap" in lieu of "interferes":
_604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. 
_
Show me in the code where I'm wrong!


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## Yikes (May 10, 2019)

ADAguy said:


> The key code wording with regards to your question is : "If provided". If you do, your comment may be seen as valid as the dispenser could then be hung from a sky hook on the wide side as long as it met the 7- 9" and the reach ranges. Try to imagine that?



Yes, the sky hook is allowable by code and it could be 20' away from the toilet on the wide side, as long as it meets the 7-9" in front of the toilet, the allowable dispenser height per 604.7.

I'm not saying you have to like it.  I don't like it either.  I'm only saying the code allows it.  Show me where I'm wrong.

Likewise regarding the word "shall": you did not provide a code reference.  Please provide one, otherwise I'm going to assume you're looking at 11B-604.7,  "Toilet paper dispensers shall comply with...".
This sentence does not say you shall provide a toilet paper dispenser.
It says that toilet paper dispensers shall comply with the dimensional requirements of 11B-604.7.

Analogy: the state says my car shall comply with the requirements of the Dept.of Motor Vehicles.  But my state does not require me to own a car.

Show me in the building code, plumbing code, etc. where it requires toilet paper, or a toilet paper dispenser, to be provided.  The only place I've found it is in health codes, such as for food retail facilities :
_114250. Clean toilet rooms in good repair shall be provided and conveniently located and accessible for use by employees during all hours of operation. The number of toilet facilities required shall be in accordance with applicable local building and plumbing ordinances. Toilet tissue shall be provided in a permanently installed dispenser at each toilet._​
Notice that the health code had to go out of its way to mention the T.P. (and it's only required for employees!) because the building and plumbing codes do not address it.

P.S. I'm not trying to troll anyone here.  I'm trying to point out the limitations of the building codes in addressing real-world conditions.


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## ADAguy (May 10, 2019)

In Cuba we found they had attendants who "rationed" the TP and kept the places "clean".


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## mark handler (May 11, 2019)

Yikes said:


> mark handler:  "Interferes with clear space?"
> Quoting the code, which uses the term "overlap" in lieu of "interferes":
> _604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
> _
> Show me in the code where I'm wrong!


The Intent


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## mark handler (May 11, 2019)

ADAguy said:


> In Cuba we found they had attendants who "rationed" the TP and kept the places "clean".


Happened to me in Paris
Attendant hands you two "sheets" of TP.


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## Yikes (May 11, 2019)

mark handler said:


> The Intent



Sounds like you agree with me, unless this website is TheBuildingIntentForum.com


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## Rick18071 (May 14, 2019)

Yikes said:


> mark handler:  "Interferes with clear space?"
> Quoting the code, which uses the term "overlap" in lieu of "interferes":
> _604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
> _
> Show me in the code where I'm wrong!



Had an inspection of an accessible toilet room that had a 6' high shelf unit in the clear space between the toilet and the sink. It was sitting on the floor partly blocking the rear grab bar. I need to quote sections of the code when I find something wrong. The only thing the code says about this is above. So I had to let it go and approve it.


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## ADAguy (May 14, 2019)

It is a moveable object but the owner has a maintenance requirement as to the clear floor space. If it obstructs, then "move it"
It may move back but you have addressed it.


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## mtlogcabin (May 14, 2019)

Shall be provided has entered one code. 
It is just a matter of time before it gets into the others

2018 ICC swimming pool code
609.5 Toilet tissue holder.
A toilet paper holder *shall be provided* at each water closet.
609.6 Lavatory mirror.
Where mirrors are provided, they shall be shatter resistant.
609.7 Sanitary napkin receptacles.
Sanitary napkin receptacles *shall be provided* in each water closet compartment for females and in the area of the showers for female use only.
609.8 Sanitary napkin dispensers.
A sanitary napkin dispenser *shall be provided* in each toilet facility for females.
609.9 Infant care.
Baby-changing tables *shall be provided* in toilet facilities having two or more water closets.


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## ADAguy (May 15, 2019)

"Spot on" mt


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## Yikes (May 15, 2019)

Glad it is in the (1) health code and (2) the swimming pool code, so far.
They are the exceptions that prove the rule: the reason it needed to be specifically in those codes for public-health-related uses is precisely because the building code and plumbing code don't already require it.

P.S., this reminds me of a meme I saw the other day, showing the kiddie pool at a water park, with the title:
"The Original Gender-Neutral Bathroom".


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## e hilton (Aug 28, 2022)

bruno2008 said:


> You can place the toilet paper holder on the top of the tank


That’s really difficult to reach from the seated position, especially if you have mobility problems and can’t twist.  And if the restroom is subject to ADA compliance, the TP has to be a couple of inches in front of the toilet.


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## steveray (Aug 29, 2022)

mtlogcabin said:


> Shall be provided has entered one code.
> It is just a matter of time before it gets into the others
> 
> 2018 ICC swimming pool code
> ...


Brought to you by Bobrick...


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## ADAguy (Aug 30, 2022)

EVER HEAR OF e-cOLI? ITS NOT PLEASANT.


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## steveray (Aug 31, 2022)

ADAguy said:


> EVER HEAR OF e-cOLI? ITS NOT PLEASANT.


Neither is cancer but there is plenty of plastics in our sealed up buildings.....


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## steveray (Sep 8, 2022)

1109.2 Toilet and bathing facilities. Each toilet room and
bathing room shall be accessible.

1101.2 Design. Buildings and facilities shall be designed and
constructed to be accessible in accordance with this code and
ICC A117.1.

604.1 General. Water closets and toilet compartments shall
comply with Section 604.

604.7 Dispensers. Toilet paper dispensers shall comply with
Sections 309.4 and 609.3. Dispensers shall not be of a type
that control delivery or do not allow continuous paper flow.

604.7.1 Location. Where the dispenser is located above the
grab bar, the outlet of the dispenser shall be located within an
area 24 inches (610 mm) minimum and 36 inches (915 mm)
maximum from the rear wall. Where the dispenser is located
below the grab bar, the outlet of the dispenser shall be located
18 inches (455 mm) minimum and 48 inches (1220 mm)
maximum above the floor.
Exception: Toilet paper dispensers that accommodate a
maximum of 2 toilet paper rolls of not more than 5-inch
(125 mm) diameter each shall be permitted to be located 7
inches (180 mm) minimum and 9 inches (230 mm) maximum
in front the of the water closet measured to the centerline
of the dispenser. The outlet of the dispenser shall be
15 inches (380 mm) minimum and 48 inches (1220 mm)
maximum above the floor.

Closest I can come to requiring them....


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## Rick18071 (Sep 9, 2022)

steveray said:


> 1109.2 Toilet and bathing facilities. Each toilet room and
> bathing room shall be accessible.
> 
> 1101.2 Design. Buildings and facilities shall be designed and
> ...


Nothing here requires any toilet paper dispensers.
Also nothing here requires them to be on the wall.


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## e hilton (Sep 9, 2022)

Rick18071 said:


> Nothing here requires any toilet paper dispensers.
> Also nothing here requires them to be on the wall.


Maybe not there, but 604.7 of ADA specifies the location of tp dispensers to be in a specific location on the side wall.  So if the facility is governed by ADA, you don’t have much choice.  And i can’t imagine getting CofO without some kind of dispenser.  You going to put a sign on the door “BYOTP”?


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## Yikes (Sep 9, 2022)

Rick18071, what I’m seeing in ADA is that a toilet must be 17-19" from a side wall, and that. TP dispenser IF provided must meet the ADA reach ranges.

ADA does not say a toilet must be provided with a toilet paper dispenser.  (Have you seen those Toto toilets with the built in bidet and air dryer?  Getting more popular in assisted living facilities.)

ADA does not say the TP dispenser, when provided, must be wall mounted.  It could be floor mounted, which probably violates the spirit of ADA but complies with the letter-of-the-law.


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## e hilton (Sep 9, 2022)

Yikes said:


> ADA does not say the TP dispenser, when provided, must be wall mounted.  It could be floor mounted, which probably violates the spirit of ADA but complies with the letter-of-the-law.


why have a portable floor stand when the sideall and grab bars are right there already?


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## Yikes (Sep 11, 2022)

e hilton said:


> why have a portable floor stand when the sideall and grab bars are right there already?


I agree.  But since this is a code forum, I wanted to clarify with code-specific parameters: 604.7.1 does not REQUIRE that a dispenser be wall mounted.  It only states the dispenser’s horizontal position relative to the front of the toilet, and its vertical elevation relative to the floor and the nearby grab bar.


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## ICE (Sep 11, 2022)

mtlogcabin said:


> Shall be provided has entered one code.
> It is just a matter of time before it gets into the others
> 
> 2018 ICC swimming pool code
> ...


I inspected a TI for a gingerbread factory that created gingerbread houses.  It was quite the place.  The owner was a man from Monaco.  Nearly the entire workforce was women from Guatemala.  The ladies were employees of a temp agency.  A manager from the temp agency was consulted during the design process.  She advised the owner to install a trash receptacle in each water closet stall….so he did that.  The County Health Department shot that down.

It was an expensive retrofit to remove the trash receptacles.  Women from Guatemala do not flush toilet paper. The sewage system in Guatemala can’t handle toilet paper.  It was a kick to hear Philippe tell the shity story.

That was twenty years ago.  FedEx pilots used to talk about their 747 reeking from gingerbread.  I should make the trip to ***** ** ******* to see if he is still there.


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## Rick18071 (Sep 12, 2022)

steveray said:


> Interesting....I wonder if they actually hit it or if they just claim they do.....





Yikes said:


> Rick18071, what I’m seeing in ADA is that a toilet must be 17-19" from a side wall, and that. TP dispenser IF provided must meet the ADA reach ranges.
> 
> ADA does not say a toilet must be provided with a toilet paper dispenser.  (Have you seen those Toto toilets with the built in bidet and air dryer?  Getting more popular in assisted living facilities.)
> 
> ADA does not say the TP dispenser, when provided, must be wall mounted.  It could be floor mounted, which probably violates the spirit of ADA but complies with the letter-of-the-law.


We do not enforce ADA in my state. We use 2018 IBC Chapter 11, and A117.1. - 2017. Chapter 11 tells us what is required and A117.1 tells us how to do it. Chapter 11 does not say anything about toilet paper or dispensers except if using swing-up grab bars that they need to be mounted on swing-up grab bars. A117.1 section 604.7 says they need to comply with 309.4 and 609.3 and does not say toilet dispensers are required, it just tells me where it is to be located if the dispenser is above or below the grab bar. It does not tell me that they are required to be above or below the grab bars at all, only where to locate it if it is above or below the grab bars.  If the toilet paper dispensers are located elsewhere the code 309.4  just says it should be usable by one hand without grasping, pinching, or twisting of the wrist. 609.7 is about grab bar spacing between the wall and projection objects.

This is the same of mirrors. Nothing in the code requires them, just their location if the owner choses to have a mirror.


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## ADAguy (Sep 13, 2022)

PA ! why must you chose not to see the forest has trees?

This has proven to be a topic reoccurring lack of/overlooked logical specifics.


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