Accessible Toilet Rooms as Defined by the ADA
Toilet Rooms Clustered Along a Corridor
Most toilet rooms in Title II and Title III facilities must comply with the Americans with Disabilities Act (ADA). The sections of the 2010 ADA Standards that cover requirements for toilet room facilities and bathing room facilities include 213, 216.8 and 603. This article will discuss the scoping requirements for toilet rooms in State and local government facilities, public accommodations, and commercial facilities. The technical requirements for the elements within toilet rooms will be discussed in other articles. The photo on the right is representative of toilet rooms clustered on a corridor.
The 2010 ADA Standards do not address the number of toilet rooms or fixtures required for a facility, but instead specify which ones must be accessible where toilet rooms are provided.
Required Toilet Rooms
2010 ADA Standard 213.2, [Toilet Rooms and Bathing Rooms], states, “Where toilet rooms are provided, each toilet room shall comply with [Standard] 603.” In other words, in new construction, ADA accessibility is required to all toilet rooms, including those for employees only. Exceptions to this Standard include the following:
1. In alterations where it is technically infeasible to comply with [Standard] 603, altering existing toilet rooms shall not be required where a single unisex toilet room complying with [Standard] 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet rooms.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by [Standard] 202.5, no fewer than one toilet room for each sex complying with [Standard] 603 or one unisex toilet room complying with [Standard] 213.2.1 shall be provided.
Portable Toilet
3. Where multiple single user portable toilet units are clustered at a single location, no more than 5 percent of the toilet units at each cluster shall be required to comply with [Standard] 603. Portable toilet units complying with [Standard] 603 shall be identified by the International Symbol of Accessibility [ISA] complying with [Standard] 703.7.2.1. The graphic on the right is representative of a portable toilet and ramp. One exception to this Standard is that portable toilet units provided for use exclusively by construction personnel on a construction site shall not be required to comply with [Standard] 213 or to be on an accessible route.
4. Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with [Standard] 603. A “cluster” is a group of toilet rooms proximate to one another. Generally, toilet rooms in a cluster are within sight of, or adjacent to, one another. The graphic below is representative of a cluster of single-user toilet rooms inside a medical office and on one floor. Single-user toilet rooms have no more than one toilet or urinal and one sink/lavatory.
Clustered Toilet Rooms on One Floor
In the graphic above the clustered single-user toilet rooms inside the office are shaded in blue. Notice that 4 of the 8 toilet rooms (50%) are larger/accessible toilet rooms dispersed across the floor. The toilet rooms on the right side of the graphic are accessed from the corridor, so they are not included as part of the cluster.
These requirements allow the use of unisex (or single-user) toilet rooms in alterations when technical infeasibility can be demonstrated. Unisex toilet rooms benefit people who use opposite sex personal care assistants. For this reason, it is advantageous to install unisex toilet rooms in addition to accessible single-sex toilet rooms in new facilities.
International Symbol of Accessibility
Compliant toilet rooms and portable toilet units must be labeled by the International Symbol of Accessibility (ISA) unless all are accessible (Standards 213.2, Ex. 3, and 216.8). The graphic on the right is representative.
Within the requirements for toilet rooms are special circumstances involving unisex toilet rooms, medical care and long-term care facilities, additions or alterations to existing facilities, technical feasibility, and alterations to primary function areas. Please see below.
Unisex (Single-Use or Family) Toilet Rooms
Unisex Toilet Room Logo
2010 ADA Standard 213.2.1, Unisex (Single-Use or Family) Toilet and Unisex Bathing Rooms, states, “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.”
Where multi-user toilet rooms are provided, accessible unisex toilet rooms cannot serve as a substitute for access to multi-user rooms, except in alterations where making multi-user rooms comply is not technically feasible. Otherwise, where multi-user and unisex restrooms are provided, both types must comply.
The International Building Code (IBC) requires accessible unisex or “family” toilet rooms in assembly and mercantile occupancies where a total of six or more toilet fixtures for each sex is required (§1108.2.1 in the 2000 IBC and §1109.2.1 in later editions). Mercantile occupancy means the occupancy or use of a building or structure, or any portion thereof, for the displaying, selling, or buying of goods, wares, or merchandise.
Medical Care and Long-Term Care Facilities [2010 ADA Standard 223]
Medical Logo
In licensed medical care and long-term care facilities, toilet rooms that are part of accessible patient or resident sleeping rooms, excluding critical or intensive care patient sleeping rooms, must comply with the ADA Standards.
Additions [2010 ADA Standard 202.2]
Additions are required to comply with requirements in the Standards for new construction. Each toilet room of an addition must comply as would be required in new construction.
Alterations [2010 ADA Standard 202.3]
When existing toilet rooms are altered, the Standards apply according to the planned scope of work. If one toilet room on a floor is altered, the Standards apply to that room only; if all toilet rooms on a floor are altered, the Standards apply to each toilet room that would be required to comply in new construction. The scope of work also determines which technical requirements apply. If some, but not all, elements in a toilet room are altered, only those elements altered must comply. If a room or space is completely altered (or built new as part of an alteration), the entire room or space must comply. The graphic below is representative of alterations to a toilet and mirror in a toilet room. Only those highlighted items need to meet the 2010 ADA Standards.
Toilet Room with Toilet and Mirror Altered
While only those elements altered are required to comply, it is advisable to maximize opportunities for accessibility in alterations. Alteration of multiple elements in a room or space may provide a cost-effective opportunity to make the entire room or space fully accessible.
Technically Infeasible
Compliance in an alteration is not required where it is “technically infeasible.” Technically infeasible is defined as “something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.” For example, combining two toilet compartments to create an accessible compartment may be technically infeasible if it would reduce the fixture count below the number required by the applicable plumbing code. Another example is if a toilet room is too small because a column encroaches on the toilet room, but enlarging the toilet room is not feasible due to the column location. See the graphic below.
Steel Column Encroaches on Toilet Room Space
Where technical infeasibility is encountered, compliance is still required to the maximum extent feasible.
Primary Function Areas [2010 ADA Standard 202.4]
When an area containing a primary function (a major activity intended for a facility) is altered or added to a facility, an “accessible path of travel” is required. The accessible path of travel, which must extend from site arrival points to the primary function area, includes provided restrooms (at least one for each sex or, if only unisex restrooms are provided, at least one unisex restroom), telephones, and drinking fountains, where provided, that serve the primary function area. The graphic below is representative of an accessible path of travel (route) to a primary function area. Notice the toilet rooms.
Accessible Route and Elements to Primary Function Area
The accessible path of travel to the altered primary function area is required to the extent that it does not cost more than 20% of the total cost of the work to the primary function area. Compliance is required up to the point this cost cap is reached, even where it does not result in a fully accessible path of travel.
SUMMARY
In summary, most toilet rooms in Title II and Title III facilities must comply with the ADA Standards. The 2010 ADA Standards do not address the number of toilet rooms or fixtures required for a facility, but instead specify which ones must be accessible where toilet rooms are provided. In new construction, ADA accessibility is required to all toilet rooms, including those for employees only. The 2010 ADA Standards specify the location of toilet rooms in two instances:
Where toilet rooms are provided in multi-story facilities that are exempt from the requirement for vertical access between stories (Standard 206.2.3, Ex. 1 or 2), an accessible toilet room must be provided on a story that is connected to an accessible entrance by an accessible route (Standard 213.1). Toilet rooms on other stories must fully comply as well.
In alterations where it is technically infeasible to make men’s and women’s rooms comply, an accessible unisex toilet room is permitted as an alternative if it is located in the same area and on the same floor as the existing toilet rooms (Standard 213.2, Ex. 1).