# Restroom access/egress



## Examiner (Oct 27, 2009)

I was in a local chain Drug Store and noticed some things that I think are Code and ADA issues.

What do you think?

1.	The restrooms were in the back area and did not have any signage for the location of the restrooms.

2.	The restrooms were not identified to be employee or public.

3.	The door on the back wall to get to the restrooms was also a door to the storage area and directly in the line of travel was the back exterior EXIT Door.  The exterior EXIT Door had a display stand in front of it.  There were not any signs on or above the door in the back wall advising you that the door was part of the Exit Access.  In fact I do not remember seeing any EXIT signs except maybe near the front door.

4.	The employee had to take me to the restroom’s locations and unlock the restroom door.  The restroom door had a push button combination lock mounted on the door at about my chest height.  I’m 6-feet tall.  The door also had a latching lever handle at the standard door handle height.

5.	Inside the restroom to get out you had to push the door lever handle down and push down a small bar lever (located at the height of the combination lock) together in order to get out.  I found this out after trying to get out by pushing the levers down one by one.

Seems to me that this national chain of Drug Stores with the same floor plan and design has some Code and ADA issues, can you name them?

Use any code and year it is a prototypical store plan.


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## JBI (Oct 27, 2009)

Re: Restroom access/egress

Ex - You didn't indicate year and version of Code (or year of construction/substantial alteration).


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## mark handler (Oct 27, 2009)

Re: Restroom access/egress

1. The restrooms were in the back area and did not have any signage for the location of the restrooms.

Lack of Signage is Violation of ADA door in the rear is common

2. The restrooms were not identified to be employee or public.

Lack of Signage is Violation of ADA

3. The door on the back wall to get to the restrooms was also a door to the storage area and directly in the line of travel was the back exterior EXIT Door. The exterior EXIT Door had a display stand in front of it. There were not any signs on or above the door in the back wall advising you that the door was part of the Exit Access. In fact I do not remember seeing any EXIT signs except maybe near the front door.  If it is a required exit, Travel through storage area "May" be a violation depending on code year built, Lack of signage is a violation of fire and building codes, Blocked door a Violation of fire code

4. The employee had to take me to the restroom’s locations and unlock the restroom door. The restroom door had a push button combination lock mounted on the door at about my chest height. I’m 6-feet tall. The door also had a latching lever handle at the standard door handle height.

If it is a required exit, locked door is a violation of fire and building codes 

5. Inside the restroom to get out you had to push the door lever handle down and push down a small bar lever (located at the height of the combination lock) together in order to get out. I found this out after trying to get out by pushing the levers down one by one.

need to see, cant tell by description


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## georgia plans exam (Oct 27, 2009)

Re: Restroom access/egress

Welcome Mr. Handler.

GPE


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##  (Oct 27, 2009)

Re: Restroom access/egress

Why does a drug store have to have a public bathroom?


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## vegas paul (Oct 27, 2009)

Re: Restroom access/egress

tigerloose - because IBC 2902.4 says so!  any facility that is open to the public, customers, visitors, etc. requires public, accessible restrooms (the drug store requires two).


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##  (Oct 27, 2009)

Re: Restroom access/egress

vegas paul,

California didn't adopt chapter 29 of the IBC.  Good thing too because if what you say is correct every business would require a public bathroom and ADA compliant.  Think of that, from a dry-cleaner to a car-wash, the shoe shop to the flower shop all with an ADA bathroom.


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## brudgers (Oct 27, 2009)

Re: Restroom access/egress

If they have a toilet room it needs to meet ADAAG.

Doesn't matter if it's for employees, customers, inmates, or whatever.


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## Gene Boecker (Oct 28, 2009)

Re: Restroom access/egress

So, did we figure out yet where this drug store is located and when it may have been built?

Like Mark Handler says, things may need to be done to make it more friendly but it may have been built under a code that allowed for the restrooms to be located where they are - and well before teh ADA was enacted.

Yes, it has to meet ADA - but that doesn't necessarily mean it needs to meet the requirements for new construction if it was built awhile back.

So, what's the skinny?


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## vegas paul (Oct 28, 2009)

Re: Restroom access/egress

tigerloose - OK, I understand now that CA did not adopt ch. 29, but in answer to your question... Of course I would want every tenant/business to have a public restroom, either inside their space or within 500 ft. in a common area!  Where else are customers going to go?  I don't know about you, but I am not inclined to spend money when I'm crossing my legs in agony!

We require every business open to the public to comply with ch. 29, and there are a lot more customers remaining in the stores/car washes/businesses, spending their money because of it!


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## brudgers (Oct 28, 2009)

Re: Restroom access/egress



			
				Gene Boecker said:
			
		

> So, did we figure out yet where this drug store is located and when it may have been built?Like Mark Handler says, things may need to be done to make it more friendly but it may have been built under a code that allowed for the restrooms to be located where they are - and well before teh ADA was enacted.
> 
> Yes, it has to meet ADA - but that doesn't necessarily mean it needs to meet the requirements for new construction if it was built awhile back.
> 
> So, what's the skinny?


There's not really any grandfathering when it comes to ADAAG.

Regardless of when it was built, non-compliant is non-compliant.

After nearly 20 years since ADA became law, it's going to be a tough sell in Federal court that there was no opportunity to remove architectural barriers.

Particularly with something like a chain drugstore given the frequency with which they are refurnished and renovated.


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## Examiner (Oct 28, 2009)

Re: Restroom access/egress

Thanks for the responses.  I will make a quick comment and later will take more time to review the responses.  California may have not adopted Chapter 29 of the IBC but did thy adopt the IPC.  Chapter 4 of the IPC is the same as Chapter 29 in the IBC.  They put Chapter 29 in the IBC for Architects to determine fixture counts without having to purchase the IPC.

As I stated the Drug store is a chain and they are building new stores as we speak.  Maybe I need to send a link to this code discussion to the Chain’s main office.  What do you think, should I?


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## vegas paul (Oct 28, 2009)

Re: Restroom access/egress

So if CA adopts the IPC and 403.6 requires public restrooms, then what's the question?  I gotta go potty!  Where am I going to go when I enter a tenant space intended for PUBLIC utilization???

tigerloose, you have to start enforcing the public restroom requirement.  Someday you also will be old and have to go every 30 minutes like me!!!


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## Gene Boecker (Oct 28, 2009)

Re: Restroom access/egress

Brudgers,

The ADA is the law which states that new construction must be built to provide accessibility and that existing facilities must have barriers removed that are readily achievable.  The ADA Accessibility Guidelines (ADAAG) were developed to identify those things that would be considered as compliant for accessibility needs.  It is based on the 1986 ANSI A117.1 (with a few additional twists).  If you read through all the text in 4.1 of the ADAAG it will tell you that it is only applicable to new construction, additions and alterations.  It does NOT require all existing buildings to meet the provisions of the ADAAG.   :roll:

You must read the ADA law itself to get the information about what is required to be done for existing buildings.  The extent of work is reduced from that in the ADAAG.  For example, in existing buildings you are allowed to make alterations to an existing toilet room to add grab bars in a toilet stall without the need to tear out walls or build a new unisex toilet room.  You can also add a bell at the front door to allow for a clerk to come service your needs without the need to install a ramp to get into the store.

That's why its important to know when the building was built and whether or not there are state laws that may be more restrictive than either the IBC or ADA.


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## TJacobs (Oct 28, 2009)

Re: Restroom access/egress

In Illinois, using the IL Plumbing Code, a unisex toilet room for employees is required for 5 employees or less on duty at one time and in M uses of less than 5,000 sq. ft.  Separate male and female restrooms are required where more than 5 employees are on duty at one time and separate male and female restrooms are required to be public in M uses at 5,000 sq. ft. or more.

The IL Accessibility Code has been in effect since April 1997 and would have required all new restrooms to be accessible after that date.


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## atomahutna (Oct 28, 2009)

Re: Restroom access/egress

Sometimes accessibility upgrades to bathrooms are required even in buildings that weren't originally subject to the ADA. See IBC 3409, which applies even to historic buildings.  In 3409.7 it says the accessible route to a primary function area must be accessible, and then goes on to say that "primary function areas" include toilet facilities.

So anyway, where does the accessible route stop?  Does it just have to go to the bathroom door?  Or do we just need a 36" wide door?  How about door and some clear floor space on the other side so you can get in and close the door?  Clear floor space at all fixtures?  How far do you take it?


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## Alias (Oct 30, 2009)

Re: Restroom access/egress



			
				Examiner said:
			
		

> Thanks for the responses.  I will make a quick comment and later will take more time to review the responses.  California may have not adopted Chapter 29 of the IBC but did thy adopt the IPC.  Chapter 4 of the IPC is the same as Chapter 29 in the IBC.  They put Chapter 29 in the IBC for Architects to determine fixture counts without having to purchase the IPC.


Examiner -

Last code cycle CA was still under the UPC with state amendments, not the IPC.  Even with these codes, this type of installation in a new building would not be approved.

If it is an existing structure, unless they do a major TI, it is not required to change the bathroom configuration.

I will also say that it is a direct violation of fire codes to have an exit that is locked and blocked.  I'd get our local fire marshal to take a look and write them up.

Sue, living la vida loca in the land of fruits and nuts


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