Accessible toilets in Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). The sections of the 2010 ADA Standards that cover requirements for toilets include 213.3.2 and 604. This article will discuss the ADA scoping and technical requirements for toilet installations in State and local government facilities, public accommodations, and commercial facilities, that are not in a stall/compartment. Common toilet installations include grab bars on the adjacent wall and the rear wall behind the toilet, a toilet paper dispenser, and a toilet seat cover dispenser. The photo above is representative of a toilet installation. The 2010 ADA Standards often refer to toilets as water closets.

2010 ADA Standard 213.3.2, Water Closets, states, “Where water closets are provided, at least one shall comply with [Standard] 604.” Standard 604 provides the technical information regarding accessible toilet installations.

TOILET CLEARANCE

The ADA compliant toilet installation starts with a clearance space around the toilet. 2010 ADA Standard 604.3.1, [Water Closet, Clearance] Size, states, “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.” This Standard applies to toilets that are not installed in a toilet stall. The graphic below is representative.

This required clearance is necessary to facilitate transfer from a wheelchair to/from the toilet seat. The graphic below is representative.

For this reason it is not allowed for some other elements, such as sinks, and the arc of a pedestrian entry/exit door to overlap the toilet clearance space. 2010 ADA Standard 604.3.2, [Water Closet] Overlap, states, “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 [like a sink or trash can] shall be located within the required water closet clearance.” The graphic below is representative.

In the graphic above notice that the clear space of the sink can overlap the clearance around the toilet, but not the sink itself.

TOILET LOCATION

The toilet itself is usually located in one corner of a toilet room. This is important to provide reach access for grab bars that will be installed on one adjacent wall and on the rear wall behind the toilet. The spacing from the adjacent walls to the toilet is important.

2010 ADA Standard 604.2, [Water Closet] Location, states, “The water closet shall be positioned with a wall or partition to the rear and to one side. The centerline of the water closet shall be 16 inches (405 mm) minimum to 18 inches (455 mm) maximum from the side wall or partition. Water closets shall be arranged for a left-hand or right-hand approach.” The graphic on the right is representative. To verify a correct installation the spacing at the front and rear of the toilet seat should be taken. There is an allowance in this Standard for differences in an ambulatory stall.

When installed in a corner as shown above, it is important for the flush handle to be located on the transfer side of the toilet, so the individual can reach the handle as easily as possible. 2010 ADA Standard 604.6, [Water Closet] Flush Controls, states, “Flush controls shall be hand operated or automatic. Hand operated flush controls shall comply with [Standard] 309. Flush controls shall be located on the open side of the water closet except in ambulatory accessible compartments complying with [Standard] 604.8.2.” The graphic on the left is representative of a flush control on the transfer/open side of the toilet.

In ambulatory stalls the handle can be on either side. Those newer toilets with a flush button on top of the water tank do not comply with the ADA Standards for wheelchair accessible toilets.

2010 ADA Standard 604.4, [Water Closet] Seats, states, “The seat height of a water closet above the finish floor shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum measured to the top of the seat. Seats shall not be sprung to return to a lifted position.” The graphic on the right is representative of this Standard.

GRAB BARS

Grab bars for water closets should comply with Standards 604.5 and 609. Grab bars should be provided on the side wall closest to the water closet and on the rear wall. There are some exceptions for grab bar installations in single occupant toilet rooms, residential installations, and in prisons. Reinforcement in the walls for grab bars must be sufficient to permit the installation of rear and side wall grab bars that fully meet all accessibility requirements including, but not limited to, required length, installation height, and structural strength.

2010 ADA Standard 604.5.1, [Water Closet, Grab Bar] Side Wall, states, “The side wall grab bar shall be 42 inches (1065 mm) long minimum, located 12 inches (305 mm) maximum from the rear wall and extending 54 inches (1370 mm) minimum from the rear wall.” The graphic below is representative. A common discrepancy on the side wall grab bar is that the grab bar is mounted too close to the rear wall, so it does not extend at least 54 inches from the rear wall.

2010 ADA Standard 604.5.2, [Water Closet, Grab Bar] Rear Wall, states, “The rear wall grab bar shall be 36 inches (915 mm) long minimum and extend from the centerline of the water closet 12 inches (305 mm) minimum on one side and 24 inches (610 mm) minimum on the other side.” The graphic below is representative of this Standard.

There are several exceptions for the rear grab bar installation that allow for different lengths of the rear grab bar.

Exception 1 states, “The rear grab bar shall be permitted to be 24 inches (610 mm) long minimum, centered on the water closet, where wall space does not permit a length of 36 inches (915 mm) minimum due to the location of a recessed fixture adjacent to the water closet.” The graphic below is representative of this exception where the sink is recessed relative to the rear wall behind the toilet.

Exception 2 states, “Where an administrative authority requires flush controls for flush valves to be located in a position that conflicts with the location of the rear grab bar, then the rear grab bar shall be permitted to be split or shifted to the open side of the toilet area.” The graphic below is representative of a split rear grab bar.

The graphic below is representative of a rear grab bar that has been shifted completely because the flush valve is located in a position that conflicts with the location of the rear grab bar. Note that the shift is allowed to the open side only.

2010 ADA Standard 609 covers grab bar issues such as cross section sizes, spacing around the grab bars, fittings, position, and structural strength. Spacing above and below the grab bars is one of the most common discrepancies found in grab bar installations.

2010 ADA Standard 609.3, [Grab Bar] Spacing, states, “The space between the wall and the grab bar shall be 1½ inches (38 mm). The space between the grab bar and projecting objects below and at the ends shall be 1½ inches (38 mm) minimum. The space between the grab bar and projecting objects above shall be 12 inches (305 mm) minimum. The graphic on the right is representative of this Standard.

The ICC A117.1 Standard for Accessible and Usable Buildings and Facilities, which is referenced by the International Building Code, requires an 18” min. vertical grab bar at water closets [toilets]. The ADA Standards do not require this grab bar but allow a second grab bar to be within the 12” clearance above the horizontal grab bar (§609.3) if there is a separation of 1½” min. The graphic below is representative of a vertical grab bar at the toilet.

DISPENSERS

Common dispensers associated with toilet installations are the toilet paper and toilet seat cover dispensers.

2010 ADA Standard 604.7, [Water Closet] Dispensers, states, “Toilet paper dispensers shall comply with [Standard] 309.4 and shall be 7 inches (180 mm) minimum and 9 inches (230 mm) maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 15 inches (380 mm) minimum and 48 inches (1220 mm) maximum above the finish floor and shall not be located behind grab bars. Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow.” The graphic below is representative of this Standard when the toilet paper dispenser is not recessed.

If the grab bar is 36” high, a non-recessed toilet paper dispenser located above the side wall grab bar must have an outlet at exactly 48” high to accommodate both the max. reach height and the 12” min. clearance above the grab bar.

A common discrepancy is found when large toilet paper dispensers are installed. These installations frequently encroach on the side wall grab bar, or the 7-9 inch spacing from the front of the toilet. The photo below is where a large toilet paper dispenser is installed too close to the top of the side wall grab bar and too far from the front edge of the toilet.

One way to accommodate these issues with toilet paper dispensers is to recess the dispensers into the wall. Recessed toilet paper dispensers provide better access by keeping space at the water closet clear. The graphic below indicates the options for toilet paper dispensers that are recessed.

The toilet seat cover dispenser is covered in 2010 ADA Standard 205.1, [Operable Parts] General, which states, “Operable parts on accessible elements, accessible routes, and in accessible rooms and spaces shall comply with [Standard] 309.” Standard 309 requires the operable parts be within accessible reach range, usable without tight grasping, pinching or twisting the wrist, and be protected by a 36X48 inch clear space. A common discrepancy is for the seat cover dispenser to be mounted on the rear wall above and behind the toilet. The photo below is representative.

SUMMARY

Where toilets are installed in a facility, at least one of the toilets in a toilet room should comply with the ADA Standards for accessibility. Also, toilet installation components such as grab bars, a toilet paper dispenser, and a toilet seat cover dispenser should also comply. The clearance around the toilet should remain clear of the sink installation and the arc of the pedestrian entry/exit door swing.

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If you observe a facility or toilet room that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

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