Understanding what references establish your regional requirements is the most important part of accessible design. Unfortunately, it can be confusing for designers since there are so many references available.

It would be very difficult to address every standard and every local building code in one article. For the purpose of this newsletter the two standards that are most applicable for Type B residential dwelling unit bathrooms will be addressed: The Fair Housing Act Design Manual (FHADM) and the 2003 ICC/ANSI A117.1 (ANSI). Following these two documents will almost always result in a compliant and accessible bathroom design.

The Fair Housing Act requires accessibility in any new multifamily residential building first occupied after March 13, 1991 and containing four or more dwelling units. The definition of a dwelling unit is any facility used as a residence for more than a brief period of time, including condominiums, apartment houses, townhouses, vacation timeshare units, dormitories, continuing care facilities, and retirement facilities. The design requirements are found in the Fair Housing Act Design Manual (FHADM), probably the most important set of requirements for residential designers. It is most important because it is required at the national level. This means that no matter what jurisdiction (state, county, city, town, or village), most residential projects are also required to meet those standard set by the guidelines.

The second document is the 2003 ICC/ANSI A117.1 standard. Since most all states and many cities develop their own set of building code requirements, the ANSI standard is typically the one document referenced by individual building codes for accessibility. ANSI covers three types of dwelling units: Accessible Units, Type A Units, and Type B Units. Each local building code will require a unit type typically based on the dwelling unit occupancy. And each unit type has its own set of requirements for bathroom design. Accessible Units are most noted as being constructed with all accessible features in place. While Type A Units and Type B Units, on the other hand, are considered “adaptable” and some accessibility features are not required at the time of initial construction. The 2003 ANSI standard has updated its requirements for the Type B Unit to meet the FHADM requirements. Thus the Type B Unit being discussed in this article is sometimes called the Fair Housing Unit.

Copies of the FHADM and the ANSI standard should be an important part of a residential designer’s library. Copies of these important documents can be obtained at www.hud.gov and www.iccsafe.org.org.

Now that we have covered the references important to accessible design, it is time to look at the actual building blocks of a residential Type B dwelling unit bathroom. Both the FHADM and ANSI provide two options for bathroom design. FHADM provides a Specification A bathroom and a Specification B bathroom, while ANSI provides an Option A bathroom and an Option B bathroom. When a residential unit has more than one bathroom, designers can either provide all Specification A/Option A bathrooms or one (1) Specification B/Option B bathroom. The Specification B/Option B bathroom has greater access to fixtures and therefore is considered more restrictive and often larger in size. Typically, architects and designers don’t initially see the benefit of providing one bathroom with greater access. However, when one (1) Specification B/Option B bathroom is used, the remainders of all bathrooms within the unit have very few requirements that need to be satisfied. FHADM exempts additional bathrooms from maneuvering clearances at fixtures while the ANSI is even more liberal having no requirements for those additional toilet rooms.

Specification A/Option A

A Specification A/Option A bathroom is made up of three (3) fixtures: the lavatory, the water closet, and the bathing fixture. Each fixture has an associated clear floor space requirement. Both the water closet and the bathing fixture also have required reinforcements in the wall for the future installation of grab bars. Often fixtures also have location requirements that determine where a plumbing element must be located adjacent to other fixtures or walls.

Lavatory Fixture (ANSI 1004.11.3.1.1 and FHADM page 7.47)

Specification A/Option A lavatories are required to have a clear floor space that is 30 inches by 48 inches. This clear floor space must be positioned on the lavatory to allow for either a parallel or forward approach. Both clear floor spaces for the parallel or forward approaches must be centered on the fixture for compliance. Prototype Bathroom 1 and Prototype Bathroom 2 below show the clear floor space for a forward approach. Generally using a forward approach will save a few inches in the overall bathroom design. However when using this approach, the counter and lavatory must be wall hung, allowing a wheelchair to pull under the element. Cabinetry is permitted under the lavatory when using a forward approach provided the cabinetry is removable without the removal or the replacement of the lavatory. The floor finish must also extend under the cabinet. Anytime lavatory pluming is exposed it must be protected. The rim of the lavatory must be no higher than 34 inches above the finish floor.

Water Closet Fixture (ANSI 1004.11.3.1.2 and FHADM page 7.40)

Water closets in Specification A/Option A bathrooms must be provided with one (1) of three (3) allowed approaches to the fixture: a parallel approach, a forward approach, or a parallel and forward approach combination. Each approach has a required clear floor space that is located from the rear wall of the water closet and from a point 18 inches from the centerline of the fixture. Prototype Bathroom 1 below is showing a parallel approach which requires a 56 inch deep by 49 inch wide clear floor space. Both the parallel approach and the forward approach do allow for a wall hung counter and lavatory to obstruct the clear floor space as shown. Both FHADM and ANSI do specify that any fixture obstructing the clears floor space at the water closet must be positioned minimum 15 inches from the centerline of the water closet. However 18 inches is recommended since many local building codes are more restrictive in this instance. Preparation for the future installation of grab bars is required and reinforcing must be provided. See ANSI 1004.11.2 and FHADM page 6.1 for reinforcement requirements.

Bathing Fixture (ANSI 1004.11.3.1.3 and FHADM page 7.53)

While this article does not address shower compartments, we will examine the tub or tub/shower combination fixture. A Specification A/Option A bathroom requires a 30 inch minimum deep by 60 inch minimum in length clear floor space at the tub or tub/shower combination fixture. Both FHADM and ANSI do allow this clear floor space to be obstructed by either a toilet or a wall hung counter and lavatory as shown below in Prototype Bathroom 1. This obstruction is only allowed at the control end of the bathing fixture. Preparation for the future installation of grab bars is also required. Reinforcing must be provided for their future installation. See ANSI 1004.11.2 and FHADM page 6.1 for reinforcement requirements.

Door and Door Maneuvering (See ANSI 404 and FHADM page 3.1)

Contrary to popular belief, doors can swing into the bathroom and even onto the required clear floor space of bathroom fixtures. Only when a “parking space”, or a 30 inch by 48 inch unobstructed area beyond the swing of the door, cannot be provided is it necessary to swing the door outward. Doorways intended for a user to pass through are required to provide 32 inches clear opening width measured between the door stop and the face of the door open at a 90 degree angle. It should be noted that ANSI allows only 31–¾ inch opening width, however FHADM is more restrictive in this instance, requiring the 32 inches. While a 2 foot 10 inch door can provided a user with the required clear opening, a 36 inch door is highly recommended to insure compliance. Also noted in Prototype Bathroom 1 and Prototype Bathroom 2, are the required maneuvering clearances at the doors. ANSI Figure 404.2.3.1 shows required maneuvering clearances for every possible approach and door swing. Remember that these maneuvering clearance are required at both the inside and the outside of the door. A hallway adjacent to the bathroom is required to be wide enough to accommodate all applicable maneuvering clearances. As well, fixtures like the water closet can not obstruct the maneuvering clearance on the inside of the room. Special attention should also be given to the location of bathroom doors in relation to required future grab bars and grab bar reinforcement for fixtures. Prototype Bathroom 2 shows how the change in the door location can change the overall design based on required maneuvering clearances and required grab bar reinforcement.

Click to view image of Prototype Bathroom 1

Click to view image of Prototype Bathroom 2

Specification B/Option B

A Specification B/Option B bathroom, like the Specification A/Option A bathroom, is also made up of three (3) fixtures: the lavatory, the water closet, and the bathing fixture. While the requirements for the lavatory and the water closet are the same in both specifications/options, the requirements at the bathing fixture are much more restrictive in the Specification B/Option B bathroom. This typically results in a slightly larger room design to accommodate the additional requirement.

Lavatory Fixture (ANSI 1004.11.3.2.1 and FHADM page 7.47)

Specification B/Option B lavatories are required to have a floor space that is 30 inches by 48 inches clear and positioned on the lavatory to allow for either a parallel or forward approach. All clear floor spaces for the lavatory must be centered on the fixture for compliance. Prototype Bathroom 3 below shows the clear floor space for a forward approach. Cabinetry is permitted under the lavatory with the same furniture requirements as described in Specification A/Option A. The rim of the lavatory must be no higher than 34 inches above the finish floor.

Water Closet Fixture (ANSI 1004.11.3.2.2 and FHADM page 7.40)

Water closets in Specification B/Option B bathrooms must be provided with one (1) of the three (3) same approaches required in the A options: a parallel approach, a forward approach, or a parallel and forward approach combination. As in the Specification A/Option A bathroom design, both the parallel approach and the forward approach allow for a wall hung counter and lavatory to obstruct the clear floor space. Remember that both FHADM and ANSI specify that any fixture obstructing the clears floor space at the water closet must be positioned minimum 15 inches from the centerline of the water closet, however 18 inches is recommended. Preparation for the future installation of grab bars is also required. Reinforcing must be provided. See ANSI 1004.11.2 and FHADM page 6.1 for reinforcement requirements.

Bathing Fixture (ANSI 1004.11.3.2.3 and FHADM page 7.53)

The most significant difference between the A type bathrooms and the B type bathrooms is the access to the bathing fixture. Specification B/Option B bathrooms are required to have a 30 inch by 48 inch unobstructed clear floor space positioned at the control end of the fixture. Both FHADM and ANSI do not allow this clear floor space to be obstructed by any fixture or any object as shown in Prototype Bathroom 3. Once more preparation for the future installation of grab bars is also required. Reinforcing must be provided. See ANSI 1004.11.2 and FHADM page 6.1 for reinforcement requirements.

Door and Door Maneuvering (See ANSI 404 and FHADM page 3.1)

Door can swing into Specification B/Option B bathrooms and onto the required clear floor space of bathroom fixtures when the 30 inch by 48 inch “parking space” is provided beyond the swing of the door. Doorways intended for a user to pass through are required to provide 32 inches clear opening width. Maneuvering clearances at the doors is required as shown in ANSI Figure 404.2.3.1.

Click to view image of Prototype Bathroom 3

Make sure you review your local building codes before proceeding with any prototype bathroom design. Additional requirements, such as cover tub control requirements, outlets, switches, and medicine cabinets, can be found in the Fair Housing Act Design Manual and the 2003 ICC/ANSI A117.1.

As with residential dwelling unit bathrooms, when working with multi-user commercial toilet rooms it is important to determine what applicable state or local building code applies to the project.

There are two standards that are most widely used and apply to commercial toilet rooms, they are: the ICC/ANSI A117.1 – 2003 Standard for Accessible & Usable Buildings and Facilities (which applies in jurisdictions that have adopted the ANSI A117.1 standard for technical accessibility requirements) and the Americans with Disabilities Act Accessibility Guidelines (ADAAG). In July 2004, a comprehensive update of ADAAG was completed, along with an update of its guidelines for federally funded facilities covered by the Architectural Barriers Act (ABA). These new guidelines will serve as the basis for updated standards that will be used to enforce the design requirements of the ADA and the ABA. This revision is anticipated to be adopted sometime in 2010 at which time it will be referred to as the Revised ADA/ABA Accessibility Guidelines. Until the US Department of Justice adopts the Revised ADA/ABA Accessibility Guidelines for entities covered under Title III of the ADA, compliance with ADAAG must be achieved nationwide. Note – the Revised ADA/ABA Accessibility Guidelines has been adopted by DOT, USPS, and DOD.

While the 2003 ICC/ANSI A117.1 standard is widely adopted nationwide and referenced by state and local building codes for accessibility, you should always check to verify what edition of the ANSI A117.1 standard is enforceable in the region you are working in.

Wheelchair Accessible Compartment

Where compartments (stalls) are provided a wheelchair accessible compartment is also required. When working with a multi-user toilet room, one of the most common mistakes made by designers is not providing the mandatory approach to the wheelchair accessible compartment door. The following are the major requirements to be aware of:

• If the approach is to the latch side of the compartment door, the clearance between the door side of the compartment and any obstruction shall be 42 inches minimum ANSI A117.1 604.9.3 and ADAAG 4.17.5.
• The width of a Wheelchair accessible compartment is required to be 60 inches.
• If the water closet is floor mounted the depth of the compartment is required to be 59 inches
• If the water closet is wall-mounted the depth of the compartment is required to be 56 inches.
• Toilet rooms, like other accessible and usable spaces, are required to provide a 60 inch turning diameter or alternate T-turn somewhere in the room.
• Contrary to common belief, toilet room doors are permitted to swing into the 60 inch turning diameter within toilet rooms.

Grab Bars

Another common mistake is providing an insufficient number of grab bars and/or not installing them in their correct locations within the accessible compartment. (Grab bars are cited in 604.5 in both 2003 ICC/ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines, and in Section 4.17.6 of ADAAG). There are two areas in which grab bars will need to be provided; the rear wall (behind the toilet) and the side wall (closest to the water closet). While we will discuss each location’s specific requirements we must make certain that under both circumstances the distance between the grab bars and the wall does not exceed 1 ½ inches and the diameter for circular grab bars is between 1 ¼ inches to 2 inches. This is required to ensure that the arm of a wheelchair user does not slip between a larger gap during the transfer. Also, keep in mind that non circular grab bars are permitted. They have to have a 2 inch cross section dimension and 4.8 inch maximum perimeter.

Rear wall grab bars: Grab bars behind the water closet must be 36 inches in length. They must be a minimum of 12 inches between wall and centerline of water closet and an additional 24 inches minimum between centerline and transfer side of water closet. In instances where the lavatory or other fixtures are required to be recessed so that the necessary clear floor space for the water closet can be achieved, the rear grab bar is permitted to be 24 inches in length.

Side wall grab bars: A 42 inch long parallel grab bar must be located 12 inches maximum from rear wall and extend 54 inches minimum from rear wall. ANSI A117.1 requires a vertical grab bar as well (this requirement is not found in ADAAG or Revised ADA/ABA Accessibility Guidelines). A vertical grab bar 18 inches minimum in length must be provided with the leading bottom edge between 39 inches and 41 inches above the floor and with the center line located between 39 inches and 41 inches from the rear wall.

Water Closets

• While water closets are required to be 16 to 18 inches from the adjacent/parallel wall in ANSI A117.1 and Revised ADA/ABA Accessibility Guidelines, ADAAG stipulates that the centerline shall be 18 inches from the side wall (ADAAG 4.17.3)
• The height between floor and toilet seat is required to be 17 to 19 inches above the floor.
• Flush valves shall be located on the wide-side of the water closet.
• The distance between the centerline of the water closet and fixture or wall is 42 to 44 inches.
• No other fixtures are permitted to be located in the clear floor space required for the water closet as it is necessary for a wheelchair user to transfer onto the water closet.

Toilet Paper Dispensers

The requirements for a toilet paper dispenser can easily be overlooked and are often a last minute add-in when designing an accessible stall. However, Special care should be taken to ensure that toilet paper dispensers are located properly to prevent the need for relocation after an incorrect installation has occurred. This can be costly and time consuming especially on projects of large magnitude.

Toilet paper dispensers are required to be centered 7 to 9 inches in front of the water closet and 15 to 49 inches above the floor. Also, they must not be located closer to 1 ½ inches below the parallel grab bar or 12 inches above. If this requirement is not met the toilet paper dispenser will interfere with the functionality and will require relocation.

Urinals

ADAAG requires that where urinals are provided an accessible urinal shall be provided. An accessible urinal is either the stall type or wall hung with the rim no higher than 17 inches above the finished floor. IBC and Revised ADA/ABA Accessibility Guidelines provide an exception from providing an accessible urinal if only one urinal is provided in the toilet room.

Ambulatory Stalls

Ambulatory accessible compartments are required when there are 6 (six) or more water closets and urinals (both combined) in a toilet room. As with a wheelchair accessible compartment a 42 inch-wide approach is required to an ambulatory compartment as well. The compartment is required to be a minimum of 60 inches in length and must be 36 inches wide.

Make sure you review your local building codes before proceeding with any prototype bathroom design. Additional requirements can be found in the 2003 ICC/ANSI A117.1.

Click to view layout image of bathroom stall

Single Use Toilet Rooms – sometimes referred to as Unisex Toilet Rooms – are scoped in the Revised ADA/ABA Accessibility Guidelines in Section 213.2 and also in the International Building Code (2006 IBC – Section 1109.2.1).

The IBC requires the installation of a unisex toilet room in assembly and mercantile occupancies where an aggregate of six or more male and female water closets is required. The unisex toilet room is provided in addition to the other accessible toilet rooms provided. The Revised ADA/ABA Accessibility Guidelines and ADAAG will permit the use of a unisex toilet room in alterations where it is technically infeasible to alter existing toilet rooms to be accessible. Keep in mind that ADAAG, the Revised ADA/ABA Accessibility Guidelines and the IBC require access to toilet/bathing facilities (and fixtures) where they are provided. Access is required to all toilet rooms and bathrooms provided for public or common use. “Common use” includes those serving a defined or restricted group of occupants (e.g., employees, students). Where toilet or bathrooms individually serve multiple public or common use spaces of the same type required to be accessible (e.g., patient exam rooms), then access is required to each toilet or bathroom. The plumbing code typically determines how many fixtures must be provided within toilet rooms.

Single-use toilet rooms benefit people who use attendants and are a good consideration in occupancies with high traffic, such as shopping centers and airport terminals, hence the requirement in the IBC for the installation of unisex toilet rooms in Assembly and Mercantile occupancies when an aggregate of six or more male and female water closets is required. Accessible unisex restrooms cannot be used as a substitute for accessible multi-user restrooms (except in alterations where making existing restrooms fully accessible is not technically feasible).

There is an Exception in ADAAG, the Revised ADA/ABA Accessibility Guidelines and the IBC for Toilet rooms designed for use by a single occupant of a specific space, which allows the toilet room to be designed to be “adaptable” so that accessible elements can be installed when needed after construction. This allows structural reinforcement or blocking for later installation of grab bars and removable base cabinetry below lavatories. It is not intended to include moving walls, relocating plumbing, replacing fixtures, widening door frames, or other work more appropriately addressed in design and construction. Rooms need to be designed to provide required clear floor space at fixtures, turning space, and door clearance.

Where portable single-user toilet or bathing units are provided at exterior sites, at least 5%, but no less than one, must be accessible at each location. (This does not apply to units used only by construction personnel at construction sites). Portable units are subject to the same technical criteria applicable to permanent facilities.

While none of the federal guidelines or model codes specify room dimensions for single-use toilet rooms, key considerations include the configuration of water closets and lavatories, clear floor spaces required at fixtures, turning space, the location and swing of doors, and maneuvering space at doors. An important consideration is whether or not space for side transfers is provided. Doors can swing into the turning space but not the clear floor space required at fixtures. A key difference between ADAAG and the Revised ADA/ABA Accessibility Guidelines and ANSI A117.1 is the clearance required at the water closet. While ADAAG will allow a lavatory to encroach on the clear floor space required at the water closet, the Revised ADA/ABA Accessibility Guidelines and ANSI A117.1 – 2003 require that a minimum of 56 inches X 60 inches of clearance is provided at the water closet and no other fixtures can encroach on this clear floor space. Another key difference between ADAAG and ANSI A117.1 is the requirement for a vertical grab bar at the water closet – explained in more detail below.

Below are some of the key design features for unisex/single use toilet rooms:

Maneuvering Clearance at Toilet Room Door

The door leading into a single use toilet room must comply with the maneuvering clearance requirements found in ADAAG 4.13.6. The maneuvering clearance requirements applicable in ADAAG are the same in ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines.

Turning Space & Door Swing

All 3 standards (ADAAG, the Revised ADA/ABA Accessibility Guidelines and ANSI A117.1) require that a turning space is provided within the room (either a 60 inch turning diameter or a T-Shaped wheelchair turning space). The clear floor spaces, clearance at fixtures and turning spaces are permitted to overlap. Per ANSI A117.1 603.2.3 and the Revised ADA/ABA Accessibility Guidelines Exception 2, when the toilet room is for individual use and a clear floor space of 30 inches X 48 inches minimum is provided within the room beyond the arc of the door swing, the door can swing into the clear floor space for a fixture.

Water Closets

*Note that ADAAG and ANSI A117.1 have allowances for different fixture heights when used primarily by children*

Clear Floor Space: ADAAG 4.16.2 requires that the clear floor space for water closets not in stalls must comply with Figure 28 (below). As stated above however, ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines require that a minimum of 56 inches X 60 inches of clear floor space must be provided at the water closet. This difference is illustrated in the two figures below.

Click for here for larger image.

The first two layouts above do not comply with clearance requirements at water closets in jurisdictions that reference ANSI A117.1. These layouts do not comply with the Revised ADA/ABA Accessibility Guidelines either. See below.

Revised ADA/ABA Accessibility Guidelines/ANSI A117.1 2003 604.3

The additional clearance at the water closet provides the space necessary for someone to perform a side transfer to the water closet as illustrated below:

Centerline of the Water Closet: While water closets are required to be 16 to 18 inches from the adjacent/parallel wall in ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines (Sections 604.2) ADAAG stipulates that the centerline shall be 18 inches from the side wall (ADAAG 4.16.2 and Figure 28)

Seat Height: The height of water closets shall be 17 inches to 19 inches measured to the top of the toilet seat (ADAAG 4.16.3, ANSI A117.1 & Revised ADA/ABA Accessibility Guidelines Section 604.4.

Grab Bars

Grab bar requirements are found in Section 604.5 in both 2003 ICC/ANSI A117.1 and The Revised ADA/ABA Accessibility Guidelines and 4.16.4 in ADAAG. There are two areas in which grab bars will need to be provided; the rear wall (behind the water closet) and the side wall (closest to the water closet). While we will discuss each location’s specific requirements we must make certain that under both circumstances the distance between the grab bars and the wall is 1 ½ inches and the diameter for circular grab bars is between 1 ¼ inches to 2 inches. This is required to ensure that the arm of a wheelchair user does not slip into a larger gap during the transfer. Also, keep in mind that non circular grab bars are permitted. They have to have a 2 inch cross section dimension and 4.8 inch maximum perimeter. Note that there is an exception in the IBC, ADAAG and the Revised ADA/ABA Accessibility Guidelines for grab bars not to be installed in a toilet room for a single occupant accessed only through a private office and not for common use or public use, provided that reinforcement has been installed in walls and located so as to permit the installation of grab bars.

Rear wall grab bars: Grab bars behind the water closet must be 36 inches in length. There must be a minimum of 12 inches between the wall and the centerline of water closet and an additional 24 inches minimum between centerline and transfer side of water closet. In instances where the lavatory or other fixtures are required to be recessed so that the necessary clear floor space for the water closet can be achieved, the rear grab bar is permitted to be 24 inches in length. (ANSI A117.1 & Revised ADA/ABA Accessibility Guidelines Section 604.5.2, ADAAG 4.16.4)

Fixed side wall grab bars: ADAAG 4.16.4, Section 604.5.1 of ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines require that a 42 inch long parallel grab bar must be located 12 inches maximum from the rear wall and extend 54 inches minimum from rear wall. ANSI A117.1 Section 604.5.1 requires a vertical grab bar as well (this requirement is not found in ADAAG or 2004 ADAAG).This vertical grab bar 18 inches minimum in length must be provided with the leading bottom edge between 39 inches and 41 inches above the floor and with the center line located between 39 inches and 41 inches from the rear wall.

Flush Controls: ADAAG 4.16.5, ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines all require that flush controls shall be hand operated or automatic and shall be mounted on the wide side of toilet areas. ADAAG states that flush controls shall be no more than 44 in (1120 mm) above the floor. ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines require that flush controls are mounted within accessible reach ranges outlined in Section 308 of ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines.

Toilet Paper Dispensers: The requirements for a toilet paper dispenser can easily be overlooked and are often a last minute add-in when designing a unisex toilet room. However, special care should be taken to ensure that toilet paper dispensers are located properly to prevent the need for relocation after an incorrect installation has occurred. This can be costly and time consuming especially on projects of large magnitude.
Per ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines (Sections 604.7) toilet paper dispensers are required to be centered 7 to 9 inches in front of the water closet and 15 to 48 inches above the floor. Also, they must not be located closer to 1 ½ inches below the parallel grab bar or 12 inches above. If this requirement is not met the toilet paper dispenser will interfere with the functionality and will require relocation. ADAAG 4.16.6 states that toilet paper dispensers shall be installed within reach, as shown in Fig. 29(b). Dispensers that control delivery, or that do not permit continuous paper flow, shall not be used.

Lavatories
An accessible lavatory shall be provided within a single use toilet room. ADAAG 4.19 provides the scoping for accessible lavatories and The Revised ADA/ABA Accessibility Guidelines and ANSI A117.1 scope lavatories in Section 606. ADAAG requires knee clearance of at least 29 inches to the bottom of the apron, while the Revised ADA/ABA Accessibility Guidelines and ANSI A117.1 require that the knee/toe clearance complies with Section 306 of the Revised ADA/ABA Accessibility Guidelines and ANSI A117.1. See knee clearance figure below detailing compliance with Section 306.

As you can see, ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines require minimum of 27 inches of knee clearance with a maximum lavatory height of 34”.

Under all 3 standards, lavatories shall be mounted with the rim or counter surface no higher than 34 in above the finish floor.

*Note that there are exceptions for lavatory heights used primarily by children in all 3 standards*

All three standards will also require that a clear floor space 30 inches minimum X 48 inches minimum shall be provided in front of a lavatory to allow forward approach. Such clear floor space shall adjoin or overlap an accessible route. Additionally, hot water and drain pipes under lavatories shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories.

Faucets

Faucets are scoped in ADAAG 4.19.5 and shall not require any tight grasping, pinching or twisting of the wrist to operate. Hand-operated metering faucets are required to remain open for a minimum of 10 seconds per ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines (Section 606.4).

Mirrors

In all 3 aforementioned standards, mirrors are required to be installed with the bottom edge of the reflecting surface to be no mounted no higher than 40 inches maximum above the finished floor or ground. ANSI A117.1 and The Revised ADA/ABA Accessibility Guidelines (Section 603.3) states that mirrors that are not located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface to be to be mounted no higher than 35 inches above the finished floor or ground surface.

Coat Hooks & Shelves

Per ANSI A117.1 and the Revised ADA/ABA Accessibility Guidelines Section 603.4, if coat hooks or shelves are provided within a toilet room, coat hooks shall be located within accessible reaches (15 inches minimum and 48 inches maximum above finish floor). Shelves shall be 40 inches minimum and 48 inches maximum above the floor.

Toilet Room Signage

ADAAG 4.30.6 requires that signs be centered at 60” above the finished floor or ground surface. The Revised ADA/ABA Accessibility Guidelines Section 703.4.1 and ANSI A117.1 703.3.10 require that tactile characters on signs shall be located 48 inches minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.

All 3 standards require that signage is placed on the wall adjacent to the latch side of the door, where wall space permits this installation. See the figure below from the Revised ADA/ABA Accessibility Guidelines 703.4.1 for clarification:

Even the best plans can be executed incorrectly. We are often called on to do site reviews of restrooms after the owner has received a complaint from a person with a disability. If the site has been newly renovated or constructed, the owner is shocked that there are issues with access.

The first question we are asked, did my architect design the bathroom incorrectly? More often than not, the answer is the plans are drawn in accordance with the code provision. What happens is that during construction some elements were not built according to the plans. The common errors are placement of the toilet, placement of grab bars, and height of the reflecting surface of the mirror.

Toilet Placement

Currently, ADAAG requires that the center line of the toilet be 18 inches from the side wall. ICC/A 117.1 and the Revised ADA/ABA Accessibility Guidelines provide that the centerline can be 16 to 18 inches. Thus conflicting standards add to the confusion. However, mistakes we see are outside the 16 to 18 inches. For example, if the toilet is placed with the centerline more than 18 inches from the side wall, a person who needs to use the grab bars is hindered from safely transferring onto the toilet.

Toilet centerline is 24 inches from side wall

Grab Bars

We usually find the correct size of grab bar (42 inches minimum for side wall and 36 inches minimum for rear wall). It is the placement that is incorrect. Often the 42 inch side grab bar is too close to the back wall so that the grab bar does not extend the required 54 inches from the rear wall.

Rear Grab bar placement	Side Grab bar placement

Mirror

The bottom edge of the mirror’s reflecting surface cannot exceed 40 inches above the finished floor. Often the problem is that the mirror is mounted so the bottom edge of the mirror is 40 inches above the finished floor and if the mirror has a frame then the bottom edge of the reflecting surface is more than 40 inches above the finished floor. The discrepancy is the width of the frame.

How can these problems be fixed? Relocate the toilet, grab bars, and mirror so they comply with the requirements. Examples of other fixes may include adding a partition to create the correct dimension from the side wall for a toilet that is more than 18 inches from the side partition and rather than relocating the mirror above the lavatory, place a full length mirror in close proximity to the lavatory.

If you have questions about designing bathrooms in either residential or commercial applications, please contact us.

A part of the collaboration between Carnegie Mellon University and the IDeA Center is the establishment of the Rehabilitation Engineering Research Center on Accessible Transportation (RERC-APT). The mission of the RERC-APT is to “Research and develop methods to empower consumers and service providers in the design and evaluation of accessible transportation, equipment, information services, and physical environments.” Please see the RERC-APT website: www.rercapt.org for additional information.

Accessibility Services staff will be part of this worthwhile project and will focus on improving accessible transportation by working toward the development of enhanced transportation regulations and standards for building codes and federal requirements.

Currently, Accessibility Services staff is developing a course that will be included in the IDeA Center’s online training program. The course will include links to a podcast, readings, quiz questions and a discussion board. AIA credit is currently pending for the course.

Update: Accessible Transportation Facility Design & Compliance with the Revised ADA/ABA Accessibility Guidelines

The goal of this course is to enable participants to learn the minimum requirements for accessibility at transportation facilities covered under the US Department of Transportation regulations using the Revised ADA/ABA Accessibility Guidelines.

This course will provide an overview of the accessibility requirements that affect transportation facilities that fall under US DOT jurisdiction, including:

• Basic “building blocks” of accessibility (i.e. reach ranges)
• Exterior and interior accessible routes
• Ramps
• Curb ramps
• Elevators and lifts
• Accessible parking
• Doors
• Plumbing (toilet rooms, drinking fountains)
• Bus Boarding and Alighting Areas
• Bus Shelters
• Bus Signs
• Rail Platforms
• Detectable Warnings
• Rail Station Signs

Accessibility Services staff is looking forward to working on this exciting project. To register for this online course, please go to http://www.udeworld.com/training/continuing-education/registration.html

To learn more about the IDeA Center’s online continuing education program, please visit: http://www.udeworld.com/training/continuing-education.html

The remedy for this is committing to yearly accessibility training seminars, perhaps one of the most important tools Accessibility Services offers. The design professional is responsible for almost everything in our built environment: homes, offices, schools, parks, stadiums, neighborhoods, and even cities. Therefore it is very important for them to understand accessibility and to be aware of the accessibility requirements and references that govern there work. Knowledgeable architects and engineers insure that our world is a place that is accessible to all.

We encourage Architectural teams to schedule training seminars on a yearly basis for themselves, their associates, and there staff. It is necessary for accessibility to be fresh in the minds of those creating our built environment. Training classes will highlight the important elements of accessible design, clarify often confusing sections of code, and point out the references that govern our regions. It also provides an opportunity for architects and engineers to ask specific questions regarding there current projects. Seminars can be as short as one hour, designed around a lunch break. We also provide day long classes that focus on commercial or residential requirements. Many of or seminars are AIA accredited. Even more help can be achieved by bringing Accessibility Services on as an accessibility consultant. As part of your design team our staff will review plans at every level of the architecture process.

Accessibility Services is unique amongst other accessibility organization because we understand the design process and focus on working directly with those creating the built environment. Architects, engineers and design professionals including interior designers and landscape architects can all benefit from a training seminar by Accessibility Services. Please contact us to schedule a seminar in your work place today.

The final action hearings for the next generation of codes will be held next fall (October 28-November 1, 2010 in Charlotte, North Carolina). For the IEBC Committee decision to be overturned, 2/3 of the code officials present will have to vote against the historic initiative.

“Not likely,” said James Bartl Director of Code Enforcement for Mecklenburg County Government in Charlotte, North Carolina. “Our state just adopted Chapter 11 of the International Building Code and A117.1 which made people with disabilities feel as if they lost some of the benefits of the old North Carolina Accessibility Code (Volume 1C) thus they will want to support this historic initiative.”

United Spinal Association’s Accessibility Services staff introduced proposal “EB14″ mandating that “Type B” requirements be provided in residential occupancies when alterations exceed 50% of the total building area. “Type B” is the name that the International Building Code (IBC) and the American National Standard for Accessible and Usable Building & Facilities (A117.1) give to the adaptable dwelling units required to comply with the FH Act.

Testimony provided by Marsha Mazz from the US Access Board and Cheryl Kent from the US Department of Housing and Urban Development (HUD) convinced the 15 person IEBC committee and the voting members in the audience.

Newly constructed multi-family housing buildings with four or more units occupied on or after March 13, 1991 were required to comply with the FH Act. This new construction rule will be expanded to existing apartment buildings undergoing “Level III” alterations.

Residential developers have been targeted in lawsuits by State Attorney Generals in various states as well as by the United States Department of Justice (DOJ) and HUD for not complying with Fair Housing Accessibility Guidelines and their local code. Accessibility Services works with residential designers, developers and builders in responding to these complaints. The new requirement should reduce the number of violations. If the residential developer missed complying with the FH Act during initial planning and construction, large alteration projects will now trigger compliance that will be enforced by code enforcement officials.

The 2009 edition of A117.1 will be referenced by the 2012 IBC and IEBC and expands on the original Fair Housing Guidelines by requiring maneuvering clearance on the interior of unit doors, clear floor space centered on both washer and dryer, and fuse boxes provided within accessible reach ranges.

Section 3604(f) of the FH Act prohibits discrimination in the sale or rental of a dwelling and defines discrimination “in connection with the design and construction of covered multifamily dwellings” as “the “failure to design and construct those dwellings” so they are accessible. Numerous courts have held that an entity is not required to both design and construct a housing facility to be liable.

In United States v. Hartz Construction Co., Inc., 1998 U.S. Dist. LEXIS 973 (N.D. Ill 1/26/98) the court stated that interpreting the FH Act so entities could insulate themselves from liability by segregating the design and construction “is a frank absurdity”. In 2001, the court in Doering v. Pontarelli Builders, Inc., 2001 U.S. Dist. LEXIS 18856 (N.D. Ill 11/16/01) discussed all of the prior reported court decisions and concluded that the correct interpretation is that the FH Act applies to entities who either design or construct inaccessible facilities.

While the courts are more consistent in holding that architects and contractors are liable under the FH Act as long as they were involved in either the design or construction, the controversy under the FH Act seems to be when liability for the violation ends. Some courts have deemed a violation of FH Act to be a continuing violation which does not expire until the violations are corrected, Silver State v. ERGS., 362 F. Supp. 2d 1218 (2005) and Eastern Paralyzed Veterans Ass’n v. Lazarus Burman Associates, 133 F. Supp. 2d 203 (2001). Other courts have deemed a two year statute of limitations and have held different triggering events for when the two years begins to run.

Two decisions in 2008 found different triggering events when the two year statute of limitations begins to run under FH ACT in design and construction cases. The 9th U. S. Circuit Court of Appeals held that the two year limitations period started when the last certificate of occupancy for the development was issued, Garcia et al., v. Brockway, et al., 526 F.3d 456 (9th Cir. 2008). The Garcia court noted its decision was contrary to HUD guidance but noted they were not required to follow HUD’s guidance.

The United States District Court in Maryland in Kuchmas, et al. v. Towson University, et al., 553 F. Supp. 2d 556 (D. Md. 2008) refused to cut off FH ACT liability after specific events occurred. It specifically refused to follow an earlier decision rendered in 2002 in Moseke v, Miller & Smith, Inc., 292 F. Supp. 2d 492 (E.D. Va. 2002) which held that the existence of a FH ACT non-compliant building is not a continuing violation of the FH ACT and therefore claims brought against developers, architectural firms and community associations more than two years after the completion of the building’s construction were time barred. The Kuchmas court noted that all the defendants, other than the architect, remained involved in leasing the noncompliant apartments and continued to benefit from renting inaccessible units.

What these decisions provide is some guidance on when various jurisdictions begin to run the two year statute of limitations and what factors need to be considered in determining when the time begins to run.

One last word of caution, the United States Attorney General has the right to bring lawsuits in pattern and practice cases against a developer or architectural firm.

Again, the best course of action an architect or builder can take is to ensure that the design and/or construction of the housing development comply with the FH Act.

Craig has been active in the process of architecture throughout his career. His latest success was seeing the completion of Citi Field, the new ballpark for the New York Mets. His work with Populous (formerly HOK Sport) included review of the as built conditions to ensure compliance with the architectural drawings and applicable codes.

As an Architectural Specialist, Mr. Maniscalco brings important expertise and knowledge about the process of architecture including design, architectural documentation and construction administration. He is proficient in AutoCAD.

His duties at United Spinal Association include plan review, site assessments, accessibility design, accessibility training, technical assistance, and code development.

Mr. Maniscalco has a Bachelor of Architecture from the New York City College of Technology. He has won design awards including the 2007 SARA New York Design Award of Excellence for his work on the Brooklyn Ladder Company facility.

Craig can be reached at cmaniscalco@unitedspinal.org

Jimmy has been working in the field of architecture for over 10 years and has been active in the process of architecture throughout his career and has seen the completion of numerous projects, including projects in New York City. His experience ranges from single family custom residential homes to unique mixed use large scale suburban and urban complexes.

As our Architectural Specialist, Mr. Zuehl brings important expertise and knowledge about the process of architecture including design, architectural documentation and construction administration. He is also proficient in AutoCAD versions 14 to 2009.

His duties at United Spinal Association include accessibility training, technical assistance, plan review, site assessments, accessibility design and code development.

Mr. Zuehl has a Bachelor of Architecture from the San Diego New School of Architecture and Design. He also holds a minor in Urban Studies.

Jimmy can be reached at jzuehl@unitedspinal.org