# Do x-tra restrooms have to be ADA.



## MArch (Jan 27, 2016)

Here is the situation.

Complete interior renovation of a restaurant.  We provide all the toilets that are required by code, and make them ADA compliant.

However, we want to provide an extra small toilet room that is not required by code.  Does this single use toilet room (for employees only) that consists literally of just a floor mounted toilet have to be ADA compliant?

Any help would be greatly appreciated.

Thanks.


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## fatboy (Jan 27, 2016)

Yes, it must be accessible. See 1109.2 for Exceptions.


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## Pcinspector1 (Jan 27, 2016)

Agree with fatboy there appears to be no exception in the IBC acessibility chapter for an extra restroom and needs to be made accessible


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## ICE (Jan 27, 2016)

> Here is the situation.Complete interior renovation of a restaurant. We provide all the toilets that are required by code, and make them ADA compliant.
> 
> However, we want to provide an extra small toilet room that is not required by code. Does this single use toilet room (for employees only) *that consists literally of just a floor mounted toilet* have to be ADA compliant?
> 
> ...


I'm no expert on this stuff but wouldn't a hand sink with hot water be required in that little room with the toilet?

The ADA laws require that extra everything be created for the disabled but is seems extra stupid that the ADA laws mean that we must deny the able bodied of anything extra.


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## mark handler (Jan 27, 2016)

_From the U.S. Department of Justice_

If toilet rooms are provided, then each public and common use toilet room shall comply. Other toilet rooms provided for the use of occupants of specific spaces (i.e., a private toilet room for the occupant of a private office) shall be adaptable.


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## steveray (Jan 28, 2016)

*1109.2 Toilet and bathing facilities. * 

Each toilet room and bathing room shall be _accessible_. Where a floor level is not required to be connected by an _accessible route_, the only toilet rooms or bathing rooms provided within the facility shall not be located on the inaccessible floor. At least one of each type of fixture, element, control or dispenser in each _accessible _toilet room and bathing room shall be _accessible_.

*Exceptions: *

   	1. In toilet rooms or bathing rooms accessed only through a private office, not for _common _or _public use _and intended for use by a single occupant, any of the following alternatives are allowed:    	1.1. Doors are permitted to swing into the clear floor space, provided the door swing can be reversed to meet the requirements in ICC A117.1;       	1.2. The height requirements for the water closet in ICC A117.1 are not applicable;       	1.3. Grab bars are not required to be installed in a toilet room, provided that reinforcement has been installed in the walls and located so as to permit the installation of such grab bars; and       	1.4. The requirement for height, knee and toe clearance shall not apply to a lavatory.       	2. This section is not applicable to toilet and bathing rooms that serve _dwelling units _or _sleeping units_ that are not required to be _accessible _by Section 1107.    	3. Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50 percent but not less than one room for each use at each cluster shall be _accessible_.    	4. Where no more than one urinal is provided in a toilet room or bathing room, the urinal is not required to be _accessible_.    	5. Toilet rooms that are part of critical care or intensive care patient sleeping rooms are not required to be _accessible_.    	6. Where toilet facilities are primarily for children’s use, required _accessible _water closets, toilet compartments and lavatories shall be permitted to comply with the children’s provisions of ICC A117.1.


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## ADAguy (Jan 28, 2016)

MArch, the "key" word you mention here is "employee" they "may" be disabled, if not now possibly in the future and yes the health department "requires" an employee to wash their hands after toileting and before returning to work (touching door lever).


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## MArch (Feb 1, 2016)

Thanks everyone.  Very useful information.


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## nitramnaed (Oct 26, 2016)

I have a situation where I'm doing a health club and the toilet rooms are all single use.  We have met the code requirement for the minimum amount of accessible toilets and shower rooms but we provide more than that requirement.
They are all in the same area.  




steveray said:


> *1109.2 Toilet and bathing facilities. *
> 
> Each toilet room and bathing room shall be _accessible_. Where a floor level is not required to be connected by an _accessible route_, the only toilet rooms or bathing rooms provided within the facility shall not be located on the inaccessible floor. At least one of each type of fixture, element, control or dispenser in each _accessible _toilet room and bathing room shall be _accessible_.
> 
> ...



Does this meet the defintion of "Cluster" in Exception 3 above?


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## Francis Vineyard (Oct 27, 2016)

nitramnaed said:


> I have a situation where I'm doing a health club and the toilet rooms are all single use.  We have met the code requirement for the minimum amount of accessible toilets and shower rooms but we provide more than that requirement.
> They are all in the same area.
> Does this meet the defintion of "Cluster" in Exception 3 above?


2015 Code Commentary: "(The exception) specifies where toilet rooms are clustered together (i.e., entrance doors next to each other or across the hall), not all need to be accessible. In such configurations, typically found in a doctor’s office or drug test center, the requirement is reduced to a 50-percent minimum. If these toilet rooms are clustered in separate locations, such as in a multi-clinic facility, the 50-percent minimum would be applied to each cluster. A single-occupant women’s bathroom adjacent to a single-occupant men’s bathroom is not considered a cluster since they each serve a different sex. The IPC does have an allowance that would let some small occupancies have two unisex single-occupant toilet rooms, rather than having the same rooms labeled men’s and women’s (see Section 2902.2.1) If these toilet rooms are clustered, they can use this 50-percent exception since they are the same type."


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## ADAguy (Oct 27, 2016)

Interesting to note MArch that you are from NC, the home state of Ron Mace, FAIA. You do know of him? NC being one of the first states to have a code addressing access, I find your question of some concern; by its nature does it mean that it is not as enforced in NC as it is in CA and other states? Others who have provided cites to you support ADA's minimum requirements.

Love our Forum and the relevancy of the responses to questions such as this.


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## steveray (Oct 27, 2016)

nitramnaed said:


> I have a situation where I'm doing a health club and the toilet rooms are all single use.  We have met the code requirement for the minimum amount of accessible toilets and shower rooms but we provide more than that requirement.
> They are all in the same area.Does this meet the defintion of "Cluster" in Exception 3 above?



I would think so, but I would have to see it...No different than a large gang bathroom where a small fraction would be accessible (IMO the intent of the exception)...Maybe require an ambulatory if you have 6 singles?


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## Yikes (Oct 28, 2016)

ADAguy said:


> MArch, the "key" word you mention here is "employee" they "may" be disabled, if not now possibly in the future and yes the health department "requires" an employee to wash their hands after toileting and before returning to work (touching door lever).



More to the point, he said the extra non-required toilet room was for employee use only.  In other words, if I am an employee with a physical disability, I am not able to use the employee-only bathroom.  I must be sent exiled off to the general public's toilet room.  That is not "equivalent facilitation".


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## ADAguy (Oct 28, 2016)

Employee rr must comply


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