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Steven R. Jones

Toilet Compartment Access

General Comment or Question

Steven R. Jones | September 14, 2016 at 8:09AM (edited)

Hello and Good day!,

I have a code official enforcing §604.8.1.2 literally to the Figure shown in the 2010 ADA Standards and would like help to clarify their understanding if appropriate.  I believe the figure shown in the standards is not the only option that is compliant for new construction.  If the door and access were from the opposite side, although not as accessible I believe it is also §404 compliant because a self-closing door is not the same as a door with a closer?  Are both layouts shown in the attached file compliant? 

Any advise?

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  • ADA_Toilet_Compartment_Access_Question.pdf
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James L. Terry

Toilet Compartment Access

Professional Interpretation or Opinion

James L. Terry | September 20, 2016 at 9:09AM (edited)

Applicability:

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

Type of entity:

  • ADA Covered Facilities
Questions, Facts, and Assumptions:

Your figure shows two compartment door approach options, the one shown in Figure 604.8.1.2, and an alternate figure which is identical except that the door is hinged on the opposite side (still swinging outward) and the approach is from the opposite side.  So it is still a latch side approach with exactly the same dimensions, including minimum clearances.

I'm assuming that we are looking at compliance with the 2010 ADA Standards.  As far as I can recall right now, this also applies under every other accessibility standard I can remember.

Detailed Analysis:

According to 104.3 Figures, "Unless specifically stated otherwise, figures are provided for informational purposes only."

For your building official, the ICC A117.1-2009 Accessibility Standard referenced by the IBC says "104.3 Figures.  Unless specifically stated, figures included herein are provided for informational purposes only and are not considered part of the standard."

If you look at 604.8.1.2 Doors, it says, 

"Toilet compartment doors, including door hardware, shall comply with 404 except that if the approach is to the latch side of the compartment door, clearance between the door side of the compartment and any obstruction shall be 42 inches (1065 mm) minimum. Doors shall be located in the front partition or in the side wall or partition farthest from the water closet. Where located in the front partition, the door opening shall be 4 inches (100 mm) maximum from the side wall or partition farthest from the water closet. Where located in the side wall or partition, the door opening shall be 4 inches (100 mm) maximum from the front partition. The door shall be self-closing. A door pull complying with 404.2.7 shall be placed on both sides of the door near the latch. Toilet compartment doors shall not swing into the minimum required compartment area."  

When read against the plain language of the 2010 ADA Standard and the A117.1-2009, your figures are both clearly compliant.

Conclusion/Summary:

Although there may be differences in the size of compartments and door clearance or maneuvering space dimensions between states, very few if any other standards are still using figures to convey essential design requirements.  They are now trying to convey all enforceable requirements in words only.  So you should be able to convince the building official to allow the alternate design simply by referencing section 104.3 under both the ADA Standards and the IBC which is read with the ICC A117.1-2009.  If a state or local accessibility standard applies, look for the same or similar language there, usually near the front of the standard.

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