# Toilet & sink overlap



## e hilton (Sep 6, 2019)

ok, probably correctly titled “water closet and lavatory” ... 
where can i find what is allowed with regard to overlapping the clearances around the potty and sink in a commercial restroom (not residential).   For front approach the toilet requires 48” w x 66” d and the sink requires 30” x 48”.   I thought i had read somewhere that the sink can extend into the toilet space as long as it is no closer than 18”.


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## classicT (Sep 6, 2019)

If an accessible water closet, you cannot have the lavatory within the minimum clear floor space.

*A117.1-2009*
*604.3.1 Size*

Clearance around a water closet shall be 60 inches (1525 mm) minimum measured perpendicular from the side wall and 56 inches (1420 mm) minimum measured perpendicular from the rear wall.Figure 604.3.1 Size of Clearance at Water Closets





*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.
*EXCEPTION*: In residential dwelling units, a lavatory complying with 606 shall be permitted on the rear wall 18 inches (455 mm) minimum from the water closet centerline where the clearance at the water closet is 66 inches (1675 mm) minimum measured perpendicular from the rear wall.​

Even if the water closet is not accessible, it is most likely that the lavatory still is. In that case, the typical clear floor space is required.

*606.2 Clear Floor Space*

A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided.
*EXCEPTIONS: .... (MANY, see code as not listed in this post)*​*305.3 Size*

The clear floor or ground space shall be 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum.Figure 305.3 Clear Floor or Ground Space



​


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## classicT (Sep 6, 2019)

You may also be thinking of the following from the IPC (2015)

*405.3.1 Water Closets, Urinals, Lavatories and Bidets*

A water closet, urinal, lavatory or bidet shall not be set closer than 15 inches (381 mm) from its center to any side wall, partition, vanity or other obstruction, or closer than 30 inches (762 mm) center to center between adjacent fixtures. There shall be not less than a 21-inch (533 mm) clearance in front of the water closet, urinal, lavatory or bidet to any wall, fixture or door. Water closet compartments shall be not less than 30 inches (762 mm) in width and not less than 60 inches (1524 mm) in depth for floormounted water closets and not less than 30 inches (762 mm) in width and 56 inches (1422 mm) in depth for wallhung water closets.​


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## e hilton (Sep 6, 2019)

Is that from IPC or ADA?


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## Builder Bob (Sep 7, 2019)

ADA...go to ADA.gov


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## e hilton (Sep 7, 2019)

Found this ...

603.2.2 Overlap. Required clear floor spaces, clearance at fixtures, and turning space shall be permitted to overlap.


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## steveray (Sep 9, 2019)

TyJ pretty much nailed what I was thinking...


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## ADAguy (Sep 9, 2019)

e hilton said:


> Is that from IPC or ADA?



IPC


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## Tim Mailloux (Sep 9, 2019)

e hilton said:


> Found this ...
> 
> 603.2.2 Overlap. Required clear floor spaces, clearance at fixtures, and turning space shall be permitted to overlap.



Not sure what version of ANSI this reference is from, but in the 2009 version 603.2.2 is for door swings. The clearance overlap section for toilet rooms is 604.3.3 and it specifically states that no other fixtures can be located with in the required water closet clearance.

*604.3.3 Clearance 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.*


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## e hilton (Sep 9, 2019)

Ok, to clarify ... i dont want to locate the sink within the potty clearance footprint, but i do want the clearances to overlap.  My archy is telling me the clearances have to be discrete.


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## steveray (Sep 9, 2019)

The lav space, but not the lav, can be in the W/C space.....


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## classicT (Sep 9, 2019)

A clearance can overlap another clearance. Only performing one task at a time.

If your arch can't figure that out, how is he doing the 60" turning space? As an example, turning spaces almost always overlap with a fixture or door clear floor space.


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## classicT (Sep 9, 2019)

See the image below as an example of overlapping clear floor spaces.


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## Yikes (Sep 9, 2019)

e hilton said:


> Ok, to clarify ... i dont want to locate the sink within the potty clearance footprint, but i do want the clearances to overlap.  My archy is telling me the clearances have to be discrete.






Tim Mailloux said:


> 604.3.3 Clearance 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.


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## Rick18071 (Sep 12, 2019)

It always bothered me that you could have a shelf unit as pictured take up a lot of space between the toilet and the sink but you can't have a small instant water heater hung on the wall there.


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## ADAguy (Sep 12, 2019)

extends out 12 - 15" from face of wall if between WC & lav! would prevent rolling to wall if WC is a flushometer type.


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## Yikes (Sep 12, 2019)

ADAguy said:


> extends out 12 - 15" from face of wall if between WC & lav! would prevent rolling to wall if WC is a flushometer type.



Exactly.  It's crazy.  though it is practically unworkable, it is technically legal because ADAS 604.3.2 (and CBC 11B) allows "shelves" to overlap the required W.C. clearance space.


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## mark handler (Sep 13, 2019)

Rick18071 said:


> It always bothered me that you could have a shelf unit as pictured take up a lot of space between the toilet and the sink but you can't have a small instant water heater hung on the wall there.





When they say shelves, they are not saying a rack


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## Rick18071 (Sep 13, 2019)

What does it matter what kind of shelf. a 1' x 3' shelf takes the same amount of floor space no matter what kind of shelf it is.


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## mark handler (Sep 13, 2019)

Rick18071 said:


> What does it matter what kind of shelf. a 1' x 3' shelf takes the same amount of floor space no matter what kind of shelf it is.


you can wheel under mine.....


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## Rick18071 (Sep 13, 2019)

The code seems to think differently. Think protruding Objects. The shelf rack would not be considered a protruding object but a wall shelf would if it was between 27' and 80" above the floor.


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## ADAguy (Sep 13, 2019)

That appears to be a better point then letting it extend to the floor.


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## Builder Bob (Sep 13, 2019)

Still has to comply with the 4" projection rule..... Not allowed


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## Builder Bob (Sep 13, 2019)

*Common Questions*
_Are requirements for protruding objects limited to hallways and corridors?_

No, requirements for protruding objects apply to all circulation paths, including those in rooms and spaces off corridors. They apply to both interior and exterior circulation paths.

https://www.access-board.gov/guidel...he-ada-standards/chapter-3-protruding-objects

A restroom has a circulation route since the occupants have to transfer or relocate to use fixtures and elements.

Since a blind person cannot  disseminate a route without feeling the way, the entire restroom is a part of the circulation route. For better understanding see:
https://www.access-board.gov/images/videos/protrudingobjects.mp4


If you notice the interior of the building, the entire floor is yellow, not just a narrow imaginary walkway.


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## steveray (Sep 16, 2019)

Wouldn't the lav be a protruding object then?


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## Rick18071 (Sep 16, 2019)

Builder Bob said:


> Since a blind person cannot disseminate a route without feeling the way, the entire restroom is a part of the circulation route.



If this was true all toilet paper dispensers would have to be built into the the wall. This would include soap and towel dispensers and hand dryers anywhere in the toilet room, even if they are above the sink.


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## Builder Bob (Sep 16, 2019)

Hand dryer come with recess kits or a 4" slim line version, Toilet paper dispensers come with a recess to prevent more than 4" protrusion - also the ICC ANSI/ ADA give special exceptions to certain items because they are allowed...... However, the shelf (rack) system depicted earlier is not allowed.

Also to install items above the sink as indicated, a certain amount of reach is allowed as per ICC ANSI Table 



Don't shoot the messenger, this is items listed in ICC ANSI and/or ADA and experience from state agency inspections.

Remember the AHJ has the final verdict, and this is the verdict reached by consensus of four state agencies (AHJ) that our architecture office works with on new projects/ remodels/ alterations.


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## Builder Bob (Sep 16, 2019)

ON the lav, nope since it has specific guidelines it has to meet and are specifically spelled out.   The 4" protrusion is general statement that is overridden by the specific requirements for the fixture or element -


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## Rick18071 (Sep 16, 2019)

Had state accessibility auditors check my inspection work in a few building where toilet paper, soap and towel dispensers and hand dryers came out more than 4" in single user toilet rooms and they never said anything. I only had protruding issues when it is the route to multiple stalls, urinals, and lavatories but never in the required toilet clear floor space. I don't believe a clear floor space is the same as a circulation path. If you are in the clear floor space you are all ready where you want to "go" and there is nowhere else to circulate too until you are done "going".


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## Builder Bob (Sep 16, 2019)

Rick, can you explain that to the four state agencies we work with......... Just being the messenger and showing what we have to deal with at our level.


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## Rick18071 (Sep 17, 2019)

[A] 102.1 General. Where there is a conflict between a general
requirement and a specific requirement, the specific
requirement shall be applicable. Where, in any specific case,
different sections of this code specify different materials,
methods of construction or other requirements, the most
restrictive shall govern.

ICC/ANSI 117.1 section 604.3.3 has no protruding requirements and is more specific for one area (clearance around the water closet) and is specific on what can and can't be there, while ICC/ANSI 117.1 section 307 and IBC section 1003.3 "Protruding Objects" is more general because it covers all circulation paths anywhere and anything could be protruding except for handrails and door closers not just specific things.

*604.3.3 Clearance 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.*


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## Builder Bob (Sep 17, 2019)

Rick.... I agree with what you are stating, however, the state's four agencies will not ever admit they made a mistake..


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