# Does a Change of Occupancy require new Accessible restroom?



## snowroski (May 8, 2015)

In Pennsylvania with the 2009 I-codes, except for Ch.11 of the IBC and ANSI A117.1-2009.

665 square foot A-2 changing to an M.  One existing restroom is 13 square feet.

2009 IEBC 912.1 kicks me to section 605, specifically

*605.1.10 Toilet rooms.* Where it is technically in-feasible to alter existing toilet and bathing facilities to be accessible, an accessible family or assisted-use toilet or bathing facility constructed in accordance with Section 1109.2.1 of the International Building Code is permitted.  The family or assisted-use facility shall be located on the same floor and in the same area as the existing facilities.

*IBC 1109.2.1 Family or assisted-use toilet and bathing rooms.  *In assembly and mercantile occupancies, an accessible family or assisted-use toilet room shall be provided where an aggregate of six or more male and female water closets is required...

Does this mean that a family or assisted-use toilet or bathing room must be installed or not because there is not an aggregate of six or more male and female water closets required?


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## jdfruit (May 8, 2015)

need some more info on your situation;

why do you need an aggregate of six or more water closets for your project?

is there an existing accessible and code compliant restroom?

Per 605.1.10; look at the definition for technically infeasible, have you determined if the alterations to restrooms are technically infeasible?

PA statutes may be applicable for disabled access, hopefully someone from that great state can help further.


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## steveray (May 8, 2015)

It means you can do one "unisex" new or alter the other 2....IMO....

And don't miss this little honey:     101.4.4 Change in occupancy or use. Spaces undergoing a change in occupancy that would result in an increase in demand for either fossil fuel or electrical energy SHALL COMPLY WITH THIS CODE. Where the use in a space changes from one use in Table 505.5.2 to another use in Table 505.5.2, the installed lighting wattage shall comply with Section 505.5.

The death of the small tenant COU fitout....


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## mtlogcabin (May 8, 2015)

605.1.10 is telling you a family or assisted-use toilet room meeting the requirements of 1109.2 is acceptable in lieu of altering the existing existing space when technically in-feasible.

The code only requires one toilet room for this size "M" use

[P] 2902.2 Separate facilities.

Where plumbing fixtures are required, separate facilities shall be provided for each sex.

Exceptions:

1.	Separate facilities shall not be required for dwelling units and sleeping units.

2.	Separate facilities shall not be required in structures or tenant spaces with a total occupant load , including both employees and customers, of 15 or less.

3.	Separate facilities shall not be required in mercantile occupancies in which the maximum occupant load is 100 or less.


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## snowroski (May 8, 2015)

I get what you are saying and going from an A-2 to an M is a reduced occupant load,  the existing 13 SF bathroom is in such a position in the tenant space that it would require some serious renovation.

The lighting load is good for the energy code.  They are putting in an accessible changing room.

What I don't understand is why the IEBC is sending me to the section for family or assisted use when 1109.2 covers toilet and bathing facilities.

Is there some reason that it sends us to a section that had a requirement for 6+fixtures?


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## mark handler (May 8, 2015)

snowroski said:
			
		

> In Pennsylvania with the 2009 I-codes, *except for Ch.11 of the IBC *and ANSI A117.1-2009.


*except for Ch.11 of the IBC * then you proceed to quote the chapter 11

what version of the code are you quoting chapter11 from?


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## snowroski (May 9, 2015)

2012 IBC and 2009 IBC have the same language.


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## mark handler (May 9, 2015)

snowroski said:
			
		

> 2012 IBC and 2009 IBC have the same language.


Did not answer the question


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## snowroski (May 9, 2015)

mark handler said:
			
		

> snowroski said:
> 
> 
> 
> > 2012 IBC and 2009 IBC have the same language.


Did not answer the question

It does answer the question because both the 2012 and 2009 day the same thing.  Therefore it is irrelevant which one is read.  But to make you feel better,  I quoted both.


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## jar546 (May 9, 2015)

I see what happened.  Here.  snowroski stated the 2009 IBC applied _EXCEPT _for chapter 11 and the ANSI.  You did not clarify that the 2009 I-codes apply except for Chapter 11 and Appendix E are from the 2012 version.  That was the confusion.  It made it sound like accessibility from the I-Codes did not apply at all.

So Mark, the 2009 I-Codes apply except Chapter 11 and Appendix E are from the 2012 IBC which means the 2009 ANSI A117.1 is referenced.

This of course does not negate the architect, owner of builder from compliance with Federal ADA


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## jar546 (May 9, 2015)

Now I'll add my opinion.  That is a very small M space and I am sure that only 1 bathroom is required based on occupant load from the low square footage.

They only need to have 1 ADA compliant restroom which can be Unisex or whatever the new term is.

The change of use and occupancy and ADA forces the restroom upgrade.

In PA, however, if you want to claim "technically infeasible" you have to go in front of the PA L&I Accessibility Advisory Review Board, HOWEVER, they will tell you that if they give you a variance, it does not relieve you from the requirements of Federal ADA laws.


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## snowroski (May 10, 2015)

I went back and read my original post.  Definitely not clear.

I, too, agree that a new restroom is required and a single unisex would work based on led than 50 in an M.  To me, the way I was reading the code was as confusing as my first post.


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