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Larry M. Schneider

Flush Controls On Toilets

General Comment or Question

Larry M. Schneider | February 14, 2016 at 4:02PM (edited)

As we all know the requirements for the accessible toilet flush control is on the wide, open side of the toilet room and/or compartment.  With requirement's for saving of water within certain jurisdictions there are a number of toilets out there with the flush control as a button on the top of the tank.  In fact it has two parts - one for a liquid flush [les water required] and one for matter flush and they are being installed throughout the country.

With the flush control being on the top of the tank, is this a violation of the ADA requirements to be on the wide side?

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Dennis N. Miles, AIA, CBO, CASp 151

Flush Controls on Toilets

Professional Interpretation or Opinion

Dennis N. Miles, AIA, CBO, CASp 151 | October 26, 2016 at 1:10PM (edited)

Applicability:

  • New Construction
  • Alterations & Path of travel
  • Readily achievable barrier removal

Type of entity:

  • ADA Covered Facilities

Project date: February 14, 2016

Questions, Facts, and Assumptions:

2010 ADA Standards

Flush Controls for accessible toilets are require to be on the open side of the water closet

Flush Controls for accessible water closets and toilet compartments for Children’s Use shall be hand operated or automatic. Hand operated flush controls shall comply with 309.2 and 309.4 and shall be installed 36 inches (915 mm) maximum above the finish floor. Flush controls shall be located on the open side of the water closet. .

1991 ADA Standards

Water Closet Flush Controls shall be mounted on the wide side of toilet areas no more than 44 in (1120 mm) above the floor.

A4.16 Water Closets.

Flush controls for tank-type toilets have a standardized mounting location on the left side of the tank (facing the tank). Tanks can be obtained by special order with controls mounted on the right side. If administrative authorities require flush controls for flush valves to be located in a position that conflicts with the location of the rear grab bar, then that bar may be split or shifted toward the wide side of the toilet area.

 

Detailed Analysis:

2010 ADA Standards

604.6 Flush Controls. Flush controls shall be hand operated or automatic. Hand operated flush controls shall comply with 309. Flush controls shall be located on the open side of the water closet except in ambulatory accessible compartments complying with 604.8.2.

Advisory 604.6 Flush Controls. If plumbing valves are located directly behind the toilet seat, flush valves and related plumbing can cause injury or imbalance when a person leans back against them. To prevent causing injury or imbalance, the plumbing can be located behind walls or to the side of the toilet; or if approved by the local authority having jurisdiction, provide a toilet seat lid.

604.9 Water Closets and Toilet Compartments for Children’s Use. Water closets and toilet compartments for children’s use shall comply with 604.9.

604.9.5 Flush Controls. Flush controls shall be hand operated or automatic. Hand operated flush controls shall comply with 309.2 and 309.4 and shall be installed 36 inches (915 mm) maximum above the finish floor. Flush controls shall be located on the open side of the water closet except in ambulatory accessible compartments complying with 604.8.2.

1991 ADA Standards

4.16 Water Closets.

4.16.5* Flush Controls. Flush controls shall be hand operated or automatic and shall comply with 4.27.4. Controls for flush valves shall be mounted on the wide side of toilet areas no more than 44 in (1120 mm) above the floor.

A4.16 Water Closets.

A4.16.5 Flush Controls. Flush valves and related plumbing can be located behind walls or to the side of the toilet, or a toilet seat lid can be provided if plumbing fittings are directly behind the toilet seat. Such designs reduce the chance of injury and imbalance caused by leaning back against the fittings. Flush controls for tank-type toilets have a standardized mounting location on the left side of the tank (facing the tank). Tanks can be obtained by special order with controls mounted on the right side. If administrative authorities require flush controls for flush valves to be located in a position that conflicts with the location of the rear grab bar, then that bar may be split or shifted toward the wide side of the toilet area.

Conclusion/Summary:

ADA Standards 2010 - 604.6

Flush controls would be exempt if they're always automatic.  If they fail, and there is an override button or lever or switch of some kind that has to be operated, then that has to be on the open side of the water closet.  So if anybody gets to flush the toilet, everybody has to be able to flush it.  If it's a centered button that has some diameter that provides a portion of the button on the wide side of the centerline, there's an argument that says that is on the open side because there's nothing that says how far off the centerline it has to be.  There are some authorities and some advocates that say a center pressed button is not acceptable, and others who say that is, so that could be an argument if you use a center button.

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Larry M. Schneider

RESPONSE NOTICE

General Comment or Question

Larry M. Schneider | July 21, 2016 at 7:07AM (edited)

I received a notice that there was a response to our question but I see no response . . . .

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