# Employee restroom required?



## Sifu (Jun 9, 2020)

Would a small storage space, used for storage only, fit exception #2 in the 2018
IBC 2902.3 ( IPC 403.3, # 2 )?  Consider this is a larger building being carved
up into several small storage only uses.  There are no public access restrooms
within travel distances.

To me the exception is for public facilities, meaning the space is still required to
have fixtures for the employee who may access the space, even if it is for a short
time.

_[P] 2902.3 Employee and public toilet facilities. 
For structures and tenant spaces intended for public utilization, customers,
patrons and visitors shall be provided with public toilet facilities. Employees
associated with structures and tenant spaces shall be provided with toilet
facilities. The number of plumbing fixtures located within the required toilet
facilities shall be provided in accordance with Section 2902 for all users. Employee
toilet facilities shall be either separate or combined employee and public toilet
facilities.

Exception: Public toilet facilities shall not be required for:

1. Parking garages where operated without parking attendants.
2. Structures and tenant spaces intended for quick transactions, including takeout,
pickup and drop-off, public access area less than or equal to 300 square feet
(28 m2)._

As an extension ( if the answer to question above is "No" ), would the fixtures be
required to be fully accessible?  IBC 1109.2 offers an exception for a private
bathroom through a private office to be adaptable but not fully accessible.  I don't
see the storage space fitting this exception, and if it is the only fixture it would be
required to serve the entire occupant load per IBC T1004.5, which would negate
the "single occupant" limitation.

_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. Except
as provided for in Sections 1109.2.2 and 1109.2.3, 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. 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, shall be permitted
to comply with the specific exceptions in ICC A117.1.

_


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## steveray (Jun 10, 2020)

I think I could use that a basis for an argument to not have employee facilities...And actually about to have that discussion on an electrical substation that shows an "office" in the switch building....


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## ADAguy (Jun 10, 2020)

awaiting response to this, should be interesting.


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## classicT (Jun 10, 2020)

We here in Washington are fortunate enough to have an amendment to Section 2902.1 that allows no restrooms where the buildings are unoccupied, such as a storage rental facility.

*[P] 2902.1 Minimum Number of Fixtures (w/ WA Amendments)*
Plumbing fixtures shall be provided for the type of occupancy and in the minimum number shown in Table 2902.1. Uses not shown in Table 2902.1 shall be determined individually by the building official based on the occupancy which most nearly resembles the proposed occupancy. The number of occupants shall be determined by this code. Plumbing fixtures need not be provided for unoccupied buildings or facilities.​
However, for those outside of WA, I would suggest that there is no equivalent exception provided in the un-amended IBC.


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## mtlogcabin (Jun 10, 2020)

steveray said:


> And actually about to have that discussion on an electrical substation that shows an "office" in the switch building.



I would say that is a "U" occupancy

Plumbing fixtures shall be provided in the minimum number as shown in Table 2902.1 based on the actual use of the building or space. Chapter 29 is silent on the number of fixtures required for "U" occupancies and traditionally a "U" occupancy is not an Occupliable  Space by definition.

 OCCUPIABLE SPACE. A room or enclosed space designed for human occupancy in which individuals congregate for amusement, educational or similar purposes or in which occupants are engaged at labor, and which is equipped with means of egress and light and ventilation facilities meeting the requirements of this code.

Sure a maintenance worker may be in the structure for a short time and in today's world providing a desk to fill out paper work in that structure for a short time does not make it an "office". I would not require a rest room

Business
Buildings for the transaction of business, professional services, other services involving merchandise, office buildings, banks, light industrial, ambulatory care and similar uses


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## steveray (Jun 10, 2020)

Problem being the designer has not called it anything....So we will discuss...If I have to assume, I will assume the most restrictive. If the designer wants to propose something, I may accept that proposal.


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## Sifu (Jun 10, 2020)

The U classification is interesting, but most things being stored will fit neatly into S1 or S2, which the code is not silent on.  In particular, a self storage facility is named as an S1.  Also, as would be the case for a self storage facility, you could have a few hundred units, with multiple users on site at one time.  These places should offer a place to go, the alternative would stink. (see what I did there?)  In the case of the facility in my post, they are much bigger, in the order of 1000 to 2000sf, substantial time could be spent there by one or more "employees".

Ty, I really like the amendment idea.  I don't know what criteria would be used to determine what "unoccupied" means, but I am thinking a fair and consistent way could be established.  Unfortunately, my AHJ is more likely to allow it without an amendment or policy due to politics.  Based on what I know at this point I will require a bathroom, reference the code and see what happens.


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## classicT (Jun 10, 2020)

Sifu said:


> Ty, I really like the amendment idea.  I don't know what criteria would be used to determine what "unoccupied" means, but I am thinking a fair and consistent way could be established.  Unfortunately, my AHJ is more likely to allow it without an amendment or policy due to politics.  Based on what I know at this point I will require a bathroom, reference the code and see what happens.


We use a fair amount of discretion in allowing a storage unit to be classified as unoccupied. If it is the typical locker unit type, we will consider it as unoccupied as people are transient (pick-up/drop-off and leave). However, as soon as an office or sales counter is added, a public use bathroom is required.


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## mtlogcabin (Jun 10, 2020)

Sifu
In your case it is definitely a "S" occupancy and if over 300 sq ft gross building area then an accessible rest room is required along with accessible  storage space if the storage spaces are rented

1108.3 Self-service storage facilities.
Self-service storage facilities shall provide accessible individual self-storage spaces in accordance with Table 1108.3.


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## Sifu (Jun 10, 2020)

MT, I hadn't even considered 1108.3.....another case of not reading far enough.  That removes doubt.  Much appreciated.  

Sometimes an undeniable answer presents itself when a question is asked, sometimes we are forced develop a consensus when that undeniable answer isn't presented.  Either way I love having access to all the great minds on this forum.  Nobody knows everything, but as a group we sure try to figure it out!


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