Accessibility News & Review

This post is part of a series of articles on the new ADAAG-R guidelines. I will be exploring some of the more notable changes from the current version of the ADA Accessibility Guidelines for Buildings & Facilities (ADAAG). You can find a complete copy of the new ADA/ABA Accessibility Guidelines (ADAAG-R) on the Access Board’s website.
=====================================

Let me begin by saying that, even before the ADA/ABA standards become enforceable, incorporating some of the new requirements into design standards now (or at least having them at the ready) may be prudent.  In Texas, some of these differences may be reasonable bases for requesting variances.

This first segment will deal with scoping requirements, since these are generally what drive compliance.

=======================================

213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.

EXCEPTIONS: 1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.

The notable change here is that a single-user toilet room is now explicitly allowed during alterations in lieu of altering existing toilet rooms where doing so would be technically infeasible. The option is available so long as the single-user toilet room is on the same floor and in the same area as the existing nonaccessible toilet rooms. Of course, in Texas one will still need to secure a variance to do this, so we won’t see anything effectively changing at TDLR because of this exception. Please note though that this option is NOT available in new construction.

=======================================

213.2.1 Unisex (Single-Use or Family) Toilet and Unisex Bathing Rooms. Unisex toilet rooms shall contain not more than one lavatory, and two water closets without urinals or one water closet and one urinal. Unisex bathing rooms shall contain one shower or one shower and one bathtub, one lavatory, and one water closet. Doors to unisex toilet rooms and unisex bathing rooms shall have privacy latches.

We presume the logic behind defining Unisex toilet and bathing rooms by fixture count is to prevent owners from simply re-labeling existing multi-user toilet rooms as “Unisex” to avoid altering both toilet rooms in a pair, especially in light of the exception just noted in 213.2 above.  Plumbing code disallows a reduction in fixture count below current code requirements during alterations, so the tendency might be for some owners to leave all existing fixtures in place, claim technical infeasibility and alter only one of the toilet rooms, re-label it “Unisex” and thereby avoid the expense of making the second toilet room accessible.

Remember, Texas accessibility laws are far more proactive than those in most other states. The variance process in Texas makes it difficult for an owner to simply claim technical infeasibility, making this definition for us more academic than effectual.

This definition is also consequential in occupancies where plumbing code may only require one toilet room (for example, where the occupancy is under 15), or where plumbing code explicitly allows single-user toilet rooms (assembly and mercantile occupancies, for example).

=======================================

213.3.1 Toilet Compartments. Where toilet compartments are provided, at least one toilet compartment shall comply with 604.8.1. In addition to the compartment required to comply with 604.8.1, at least one compartment shall comply with 604.8.2 where six or more toilet compartments are provided, or where the combination of urinals and water closets totals six or more fixtures.

This change is huge. We are all familiar with the requirement to provide an ambulatory toilet compartment (by the way, stalls are now referred to as “compartments”) when the number of toilet compartments in a toilet room exceeds five, but now the basis for requiring an ambulatory compartment is when the combination of urinals and water closets exceeds five.

Consider the men’s toilet room with four urinals and two toilet compartments: in the new ADA/ABA, each of the toilet compartments would have to be accessible, one as a standard accessible compartment, and one as an ambulatory compartment. This is a change worth knowing if you are planning a large renovation and your building have multiple toilet rooms on each floor.

So, what exactly is a toilet compartment? The following Advisory clarifies this issue and offers some other helpful definitions.

=======================================

Advisory 213.3.1 Toilet Compartments. A toilet compartment is a partitioned space that is located within a toilet room, and that normally contains no more than one water closet. A toilet compartment may also contain a lavatory. A lavatory is a sink provided for hand washing. Full-height partitions and door assemblies can comprise toilet compartments where the minimum required spaces are provided within the compartment.

Note first that a toilet compartment is something that is “…located within a toilet room”. Next, note that a toilet compartment can be comprised of full-height walls and a standard 3’-0” door. This might seem to some like a toilet room within a toilet room, but according to this advisory, it is not because it is “located within a toilet room”. Notice also that this toilet compartment “…may contain a lavatory” and “…normally contains no more than one water closet.”

I’m not sure of too many scenarios where a toilet compartment would need more than one water closet, but I’m going to venture a guess here.  I have seen scenarios where a special toilet compartment designed for special needs students was placed within a toilet room. The compartment included two water closets, one with grab bars and one without, and could have easily included a lavatory had they chosen to install one. I evaluated it according to the standards for toilet rooms, since it looked and qualified as a room in its own right. But now, with this advisory, I know that this space only needs to comply with the requirements for toilet compartments.

A notable difference is that in toilet rooms, a turning space is required; in stalls or compartments, one is not. [Visual Alarms are required in all common-use rooms and spaces, so a separate visual alarm would be required in a toilet “compartment” with full-height walls if audible alarms are present.]

More importantly, this definition clarifies the misunderstanding that a toilet compartment becomes a toilet room just because it has full-height walls. If it is in a toilet room, it is a compartment.

Before I move on, let me also point out that lavatories are clearly defined as those fixtures used for hand-washing, and this differentiates them from sinks (which are designed or intended to be used for other uses in addition to washing hands.)

=======================================

213.3.3 Urinals. Where more than one urinal is provided, at least one shall comply with 605.

Basically, if there is only one urinal, it no longer must be a compliant urinal.

=======================================

213.3.4 Lavatories. Where lavatories are provided, at least one shall comply with 606 and shall not be located in a toilet compartment.

In the Texas Accessibility Standards (TAS 4.22.6), this restriction has always been present, so for us in Texas the change is of little consequence.

=======================================

213.3.7 Coat Hooks and Shelves. Where coat hooks or shelves are provided in toilet rooms without toilet compartments, at least one of each type shall comply with 603.4. Where coat hooks or shelves are provided in toilet compartments, at least one of each type complying with 604.8.3 shall be provided in toilet compartments required to comply with 213.3.1. Where coat hooks or shelves are provided in bathing facilities, at least one of each type complying with 603.4 shall serve fixtures required to comply with 213.3.6.

Accessible shelves are newly specified, as heretofore they generally fell into the storage category and were simply required to be located on an accessible route within accessible reach ranges. The new requirement specifies a minimum location above the finish floor of 40 inches.

Well, that is all for this segment. Next time we will look at some of the specific dimensional requirements for the elements within toilet and bathing rooms. Let me know if you have any insights into today’s article. If I’ve missed or misinterpreted something, I would like to clean it up right away.

Subscribe to Accessibility News & Review by Email

Subscribe in a reader

Filed under: Accessibility, New ADA Guidelines