Differences of ANSI Accessible, Type A, Type B, and Type C Dwelling Unit Bathrooms
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The purpose of this article is to discuss the different types of accessibility regulations and requirements that apply to Accessible, Type A, Type B, and Type C dwelling unit bathrooms. Sources included in this article are Alphabet Soup for Dwelling and Sleeping Units, ADA Requirements for Apartment Buildings, Type ‘A’ vs. Type ‘B’ in Residential Design, the International Building Code (IBC), ANSI A117.1-2009, and the FHA Design Manual (FHADM).
American National Standards Institute (ANSI) code A117.1-2009, Accessible and Usable Buildings and Facilities, is the Standard for accessibility in buildings that was processed and approved for submittal to ANSI by the Accredited Standards Committee A 117 on Architectural Features and Site Design of Public Buildings and Residential Structures for Persons with Disabilities.
The Fair Housing Act (FHA) frequently references ANSI A117.1 as a source for technical information regarding accessible installations. In other words, ANSI A117.1 contains only technical criteria, whereas the FHA, the FHA Guidelines, and HUD regulations contain both technical criteria and scoping. Therefore, when using any of the ANSI Standards, it is important to consult and incorporate the FHA, FHA Guidelines, and/or the HUD regulations.
International Building Code (IBC) Chapter 11 also covers accessibility. IBC Chapter 11 contains provisions that set forth requirements for accessibility of buildings and their associated sites and facilities for people with physical disabilities. The fundamental philosophy of the IBC regarding accessibility is that everything is required to be accessible. As such, the IBC contains scoping provisions for accessibility to include the answers for questions regarding the what, where, and how many. ANSI A117.1 provides the how.
ANSI 117.1-2009, 1001.1, [Dwelling Units and Sleeping Units, General] Scoping, states, “Dwelling units and sleeping units required to be Accessible units, Type A units, Type B units, Type C [Visitable] units, or units with accessible communication features by the scoping provisions adopted by the administrative authority, shall comply with the applicable provisions of ANSI 117.1 Chapter 10, Dwelling Units and Sleeping Units.” These different types of dwelling units are differentiated by their requirements for accessibility.
In ANSI 117.1, Accessible, Type A, Type B and Type C units are covered for accessible installations, in descending order, from the most to least accessibility requirements.
In other words, in reference to IBC Section 1107 (2006), Accessible Units have everything in place, with clearances for a frontal approach. Type A is less accessible with adaptable bathrooms and Type B sometimes known as “safe harbor” or “Fair Housing Unit” allows side approach maneuverings to primary areas with adaptable bathrooms. Again, the IBC gives the scoping of where to place accessible bathrooms, the ANSI provides the technical requirements of how to install the bathrooms.
Accessible dwelling units are also covered in the 2010 Americans with Disabilities Act (ADA) Standards for Type II and Type III facilities, which can include hotels, motels, inns, dormitories, and nursing homes. Accessible units are constructed for a person using a wheelchair to have full access to all living spaces, especially bathrooms and kitchens. As discussed above, accessible units are also covered in ANSI 117.1-2009, section 1002.1, [Accessible Units] General, which states, “Accessible units shall comply with Section 1002.” Because these two sources overlap, if there is a difference between the two on an element, the most restrictive of the two sources should be followed.
Type A dwelling units are those that are required by and defined in the International Building Code (IBC). These units are referenced in Chapter 11 of the IBC and have to comprise at least 2% of the units in R-2 occupancies so long as there are more than 20 units. R-2 occupancies are facilities containing sleeping units or more than two dwelling units where the occupants are more permanent in nature, such as apartment buildings and condominiums. The installation requirements for Type A dwelling units are specifically called out in Chapter 10 of the ANSI code, section 1003.
Frequently a multi-unit project will have 1, 2 and 3 bedroom configurations. So when providing 2% Type A units it is required to spread those out among the different configurations. These requirements are separate from FHA requirements, or Type B units.
Type A units and Accessible units are similar but not exactly the same because they are based on different federal standards. Type A (and Type B) units come from the 1988 amendments to HUD's Fair Housing Act (FHA), and were based on the 1986 ANSI A117.1. They are included in each subsequent edition of ANSI A117.1. So Type A (and Type B) units can be considered FHA units. Accessible units come from the Americans with Disabilities Act (ADA), and apply to places of public accommodation, which is usually Title III in the ADA.
Where these two federal standards (ADA and FHA) overlap is in residential facilities such as dormitories and nursing homes. For example, in a nursing home, per the 2010 ADA, 50 percent of the residents’ rooms are required to be accessible units; and per the FHA, 100 percent of the residents’ rooms are required to be FHA/Type B units. The FHA does recognize that the accessible units exceed the Type B unit requirements for accessibility. The IBC is where the requirements from both federal rules are brought together. The IBC determines the required number and Type of accessible units as shown below:
transient lodging [hotels, motels, inns] - at least 2% Type B if there are at least 20 dwelling units
rehabilitation hospitals - 100% Type B
nursing homes - 50% accessible and 50% Type B
hospitals - 10% Type B
assisted-living facilities, Group I-1, Condition 1 - 4 % Type B
assisted-living facilities, Group I-1, Condition - 10% Type B
apartment buildings with more than 20 units - 2% Type A units, dispersed by type
ANSI 1003.1, General, states, “Type A units shall comply with Section 1003.” Basic Type A toilet/bathing room features include:
Primary entrance on accessible route
Turning radiuses within the spaces on accessible routes
Reinforcement for grab bars and shower seat
Transfer clearance space at the toilet of 60X56 inches
Toilet seat height of 15-19 inches above the finished floor
Bathtub clearance full length of the tub and 30 inches deep
One accessible mirror if installed above a lavatory
Accessible door hardware [lever type recommended]
Door widths should be 32 inches minimum
Accessible door thresholds throughout the bathroom
Type B units are often referred to as “adaptable” because they have features that are considered adaptable to become accessible, such as removable base cabinets and frame blocking for future grab bars. In other words, Type B units are usable by a person in a wheelchair, but not necessarily wheelchair friendly throughout the facility.
In structures with four or more dwelling units intended to be occupied as a residence, every dwelling unit and sleeping unit intended to be occupied as a residence shall be a Type B unit. There are exceptions to this rule if the facility does not have elevator service, for sites with steep slopes, and for multi-story facilities.
Type B dwelling unit installations are regulated by ANSI A117.1, section 1004. ANSI 1004.1, [Type B Units] General, states, “Type B units shall comply with Section 1004.” Basic Type B features include:
Parallel approach at sinks and bathroom vanities are allowed
Removable base cabinets are allowed
Frame blocking for future grab bars is required
Type B units have two options for bathing rooms, Option A and Option B. This flexibility also adds to confusion about Type B units.
When a builder or developer is deciding whether to use Type A or B when designing bathrooms, it is important to consider the number of bathrooms in the dwelling unit. If there is only one bathroom, the builder may follow the specifications for either Type A or B. Type B units can have greater access to the bathtub than a bathroom designed to meet Type A requirements.
According to the FHA Design Manual, in dwelling units containing more than one bathroom, if Type A is selected as the basis for designing a bathroom, all bathrooms in the dwelling unit also must comply with the Type A requirements. If Type B is selected, only one bathroom in the dwelling unit must meet those requirements; all other bathrooms in the dwelling unit must be on an accessible route (Requirement 4), have doors with a nominal 32-inch clear opening (Requirement 3), have switches, outlets, and controls in accessible locations (Requirement 5), and have reinforced walls around toilets, tubs, and shower stalls (Requirement 6).
Visitable dwelling units are covered by ANSI 1005, Type C (Visitable) Units. ANSI 1005.1, [Visitable Units] General, states, “Type C (Visitable) dwelling units shall comply with Section 1005.” The Type C dwelling units criteria in the A117.1 were established for adoption by individual jurisdictions if they wanted a minimal level of accessibility for new single family homes. So this is a departure from the typical transient lodging and multi-family home criteria found in Type A and B dwelling units. Type C dwelling units is a method to address aging-in-place considerations for the dwelling unit. Aging-in-place modifications are designed to make a dwelling unit more livable and visitable.
For residential dwelling units in Title II and Title III facilities provided by entities not subject to HUD Section 504 regulations (Federal assistance), 2010 ADA Standard 233.3.1.1, [Minimum Number: New Construction] Residential Dwelling Units with Mobility Features, states, “In facilities with residential dwelling units, at least 5 percent, but no fewer than one unit, of the total number of residential dwelling units shall provide mobility features complying with [2010 ADA Standards] 809.2 through 809.4 and shall be on an accessible route as required by [2010 ADA Standard] 206.” Standards 809.2 through 809.4 cover accessible routes, turning spaces, kitchens and bathing/toilet rooms in residential dwelling units for Title II and Title III facilities.
Under the FHA, all “covered multifamily dwellings” intended for first occupancy after March 13, 1991 are required to be accessible. The design and construction requirements of the act must be met in buildings with four or more dwelling units and at least one elevator. For larger buildings with no elevator, ADA-modified apartments on the ground floor are required, as are compliant common use areas. A “covered multifamily dwelling” refers to any unit in a condominium, apartment building, cooperative, timeshare unit, public housing development, nursing home, or assisted living facility.
This mandate also refers to any:
Single-family home with four or more dwellings
Building with 4-plus sleeping rooms, with a shared toilet or kitchen
Carriage house units that are level on an accessible route
Townhouse (single-story, multistory units with internal elevators, or multistory units in a building with one or more elevators)
Unit with a loft or raised or sunken living room (a unit can’t have both, and all other portions of a single-story unit must be on an accessible route)