Ambulatory Accessible Toilet Compartment Federal ADA. Issues At Hand

Jul 282016

AATC

Somewhere since 2013, I and many others missed a very important Code change: Ambulatory Accessible Toilet Compartment. I highly recommend discussing this with your architects, building officials, and designers. The correction becomes devastating.

Somehow, it was felt as if I am Immanuel Kant and after reading this code, I was awakened from somber sleep. You may not know, known, or have heard of this, yet for three years, it has been the law. The impact is major.

Majority of architects are not aware.
Cities have not enforced, or remotely given plan check comments.
The impact on existing building is immense.

There are multiple scenarios that I could create and each are more costly and devastating.

If is a new construction, and the plan checkers are not aware and do not give the correction, it does not translate that the building is fine from ever installing AATC.
This will be a plan check correction forever.
If the building is existing and the correction is triggered, where are the space to enlarge existing restrooms to comply?

In a situation in Los Angeles, this high rise was required to install. Since they had too many voluntary fixtures. Let us go back for further details.

One of the ADA upgrades of the 2013 codes was:

Chapter 6: Plumbing Elements and Facilities

Ambulatory accessible toilet compartments

Description: In large Toilet Facility restrooms, an ambulatory accessible toilet compartment

(AATC) must be provided for every six fixtures including the combination of urinals and water closets. Change from previous standard: 2010 CBC Section 1115B.3.1.5 requires an AATC for every six toilet compartments (not including the urinal fixtures).

Effective date: March 15, 2012

Original source: 2010 ADA Section 213.3.1

Relevant 2013 CBC code citations: Section 11B-213.3.1, 11B-604.2, 11B-604.8.2

Notes: AATC compartments are intended for ambulatory individuals with disabilities and are provided in addition to the normal requirements for a full-size accessible toilet compartment.

The AATC dimensions have been loosened in the 2010 ADA/2013 CBC with regard to compartment width and centerline of toilet requirements.

The allowable width is now 35-37 inches rather than 36 inches absolute.
The toilet centerline measurement is 17-19 inches rather than 18 inches absolute.
Review listed code citations for more information.

These values are larger than normal existing ADA restrooms.

The keyword is: every six toilet compartments (not including the urinal fixtures).

Let us analyze this:

Count the number of Toilets (Not Urinals) and see if the number is greater than 5. Do nothing
If the number is greater than 6, then each men and women installation requires to be expanded to 17-19” centerline.

The question becomes what if:

The number of water closets are voluntary or extra beyond the need of the building.
All codes are based on people count not toilet fixture counts.

This engineer believes, the intent and body of code nearly from cover to end is based on units of people and occupancy. Therefore, if the occupancy requires only 5 toilets in the facility and the owners decided to add toilets, the 6^th fixture must not be AATC.

The original ADA requirement reads:

604.2 Location. 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, except that the water closet shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum from the side wall or partition in the ambulatory accessible toilet compartment specified in 604.8.2. Water closets shall be arranged for a left-hand or right-hand approach.

Difference between Accessible and ambulatory. (Two grab bars)

604.3 Clearance. Clearances around water closets and in toilet compartments shall comply with 604.3.

604.3.1 Size. 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.

ada2

Figure 604.3.1 Size of Clearance at Water Closets

604.3.2 Overlap. 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 shall be located within the required water closet clearance.

EXCEPTION: In residential dwelling units, a lavatory complying with 606 shall be permitted on the rear wall 18 inches (455 mm) minimum from the water closet centerline where the clearance at the water closet is 66 inches (1675 mm) minimum measured perpendicular from the rear wall.

Advisory 604.3.2 Overlap. When the door to the toilet room is placed directly in front of the water closet, the water closet cannot overlap the required maneuvering clearance for the door inside the room.

ada3

Figure 604.3.2 (Exception) Overlap of Water Closet Clearance in Residential Dwelling Units

To begin with, urinals are not included in the fixture count.

For buildings with greater than 6 water closets: My argument is as noted. If the 6^th water closets are voluntary, this should not apply.

At the End

The English of the reading below is:

Required: Therefore ………….. fixture counts are based on occupancy load. Nearly all codes are based on occupancy load.
Then at least one is Required to be ADA
If what you have designed (Required) >6 toilets
1. Only then. You need AATC
2. Logic is not reversed. Code does not read backwards.
3. Logic:
If A is the law and is required then …………………………………. provided B is true
If A is the law and required > 6 WC is provided ……………… AATC required and C is true.
Nowhere law addresses the voluntary.

Reverse Logic example: We have a small restaurant that needs one Men and one women restrooms (Say Starbucks). If they decide and not to demolish 8 toilets in the building and use all.

Is Starbucks obligated to start from C.?

If logic does not prevail, something wrong here.

IBC Code Reads

404.1 Where required. Toilet rooms and bathing facilities containing fixtures for occupants of a structure that is required to be accessible by the International Building Code shall have at least one fixture or element of each type accessible in accordance with this section and ICC/ANSI A117.1. Where water closet compartments are provided in a toilet room or bathing facility, a wheelchair–accessible compartment shall be provided in accordance with ICC/ANSI A117.1. Where six or more water closet compartments are provided in a toilet room or bathing facility, at least one ambulatory–accessible compartment shall be provided in accordance with ICC/ANSI A117.1, in addition to the wheelchair–accessible compartment. At least 50 percent of drinking fountains, but not less than one, provided on every floor shall be accessible. Accessible routes to plumbing fixtures shall be provided in accordance with the requirements of the International Building Code.

AATC

Majority of architects are not aware.
Cities have not enforced, or remotely given plan check comments.
The impact on existing building is immense.

There are multiple scenarios that I could create and each are more costly and devastating.

If is a new construction, and the plan checkers are not aware and do not give the correction, it does not translate that the building is fine from ever installing AATC.
This will be a plan check correction forever.
If the building is existing and the correction is triggered, where are the space to enlarge existing restrooms to comply?

In a situation in Los Angeles, this high rise was required to install. Since they had too many voluntary fixtures. Let us go back for further details.

One of the ADA upgrades of the 2013 codes was:

Chapter 6: Plumbing Elements and Facilities

Ambulatory accessible toilet compartments

Description: In large Toilet Facility restrooms, an ambulatory accessible toilet compartment

Effective date: March 15, 2012

Original source: 2010 ADA Section 213.3.1

Relevant 2013 CBC code citations: Section 11B-213.3.1, 11B-604.2, 11B-604.8.2

Notes: AATC compartments are intended for ambulatory individuals with disabilities and are provided in addition to the normal requirements for a full-size accessible toilet compartment.

The AATC dimensions have been loosened in the 2010 ADA/2013 CBC with regard to compartment width and centerline of toilet requirements.

The allowable width is now 35-37 inches rather than 36 inches absolute.
The toilet centerline measurement is 17-19 inches rather than 18 inches absolute.
Review listed code citations for more information.

These values are larger than normal existing ADA restrooms.

The keyword is: every six toilet compartments (not including the urinal fixtures).

Let us analyze this:

Count the number of Toilets (Not Urinals) and see if the number is greater than 5. Do nothing
If the number is greater than 6, then each men and women installation requires to be expanded to 17-19” centerline.

The question becomes what if:

The number of water closets are voluntary or extra beyond the need of the building.
All codes are based on people count not toilet fixture counts.

The original ADA requirement reads:

Difference between Accessible and ambulatory. (Two grab bars)

604.3 Clearance. Clearances around water closets and in toilet compartments shall comply with 604.3.

604.3.1 Size. 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.

Figure 604.3.1 Size of Clearance at Water Closets

Figure 604.3.2 (Exception) Overlap of Water Closet Clearance in Residential Dwelling Units

To begin with, urinals are not included in the fixture count.

For buildings with greater than 6 water closets: My argument is as noted. If the 6^th water closets are voluntary, this should not apply.

At the End

The English of the reading below is:

Required: Therefore ………….. fixture counts are based on occupancy load. Nearly all codes are based on occupancy load.
Then at least one is Required to be ADA
If what you have designed (Required) >6 toilets
1. Only then. You need AATC
2. Logic is not reversed. Code does not read backwards.
3. Logic:
If A is the law and is required then …………………………………. provided B is true
If A is the law and required > 6 WC is provided ……………… AATC required and C is true.
Nowhere law addresses the voluntary.

Reverse Logic example: We have a small restaurant that needs one Men and one women restrooms (Say Starbucks). If they decide and not to demolish 8 toilets in the building and use all.

Is Starbucks obligated to start from C.?

If logic does not prevail, something wrong here.

IBC Code Reads

AATC

Majority of architects are not aware.
Cities have not enforced, or remotely given plan check comments.
The impact on existing building is immense.

There are multiple scenarios that I could create and each are more costly and devastating.

If is a new construction, and the plan checkers are not aware and do not give the correction, it does not translate that the building is fine from ever installing AATC.
This will be a plan check correction forever.
If the building is existing and the correction is triggered, where are the space to enlarge existing restrooms to comply?

In a situation in Los Angeles, this high rise was required to install. Since they had too many voluntary fixtures. Let us go back for further details.

One of the ADA upgrades of the 2013 codes was:

Chapter 6: Plumbing Elements and Facilities

Ambulatory accessible toilet compartments

Description: In large Toilet Facility restrooms, an ambulatory accessible toilet compartment

Effective date: March 15, 2012

Original source: 2010 ADA Section 213.3.1

Relevant 2013 CBC code citations: Section 11B-213.3.1, 11B-604.2, 11B-604.8.2

Notes: AATC compartments are intended for ambulatory individuals with disabilities and are provided in addition to the normal requirements for a full-size accessible toilet compartment.

The AATC dimensions have been loosened in the 2010 ADA/2013 CBC with regard to compartment width and centerline of toilet requirements.

The allowable width is now 35-37 inches rather than 36 inches absolute.
The toilet centerline measurement is 17-19 inches rather than 18 inches absolute.
Review listed code citations for more information.

These values are larger than normal existing ADA restrooms.

The keyword is: every six toilet compartments (not including the urinal fixtures).

Let us analyze this:

Count the number of Toilets (Not Urinals) and see if the number is greater than 5. Do nothing
If the number is greater than 6, then each men and women installation requires to be expanded to 17-19” centerline.

The question becomes what if:

The number of water closets are voluntary or extra beyond the need of the building.
All codes are based on people count not toilet fixture counts.

The original ADA requirement reads:

Difference between Accessible and ambulatory. (Two grab bars)

604.3 Clearance. Clearances around water closets and in toilet compartments shall comply with 604.3.

604.3.1 Size. 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.

Figure 604.3.1 Size of Clearance at Water Closets

Figure 604.3.2 (Exception) Overlap of Water Closet Clearance in Residential Dwelling Units

To begin with, urinals are not included in the fixture count.

For buildings with greater than 6 water closets: My argument is as noted. If the 6^th water closets are voluntary, this should not apply.

At the End

The English of the reading below is:

Required: Therefore ………….. fixture counts are based on occupancy load. Nearly all codes are based on occupancy load.
Then at least one is Required to be ADA
If what you have designed (Required) >6 toilets
1. Only then. You need AATC
2. Logic is not reversed. Code does not read backwards.
3. Logic:
If A is the law and is required then …………………………………. provided B is true
If A is the law and required > 6 WC is provided ……………… AATC required and C is true.
Nowhere law addresses the voluntary.

Reverse Logic example: We have a small restaurant that needs one Men and one women restrooms (Say Starbucks). If they decide and not to demolish 8 toilets in the building and use all.

Is Starbucks obligated to start from C.?

If logic does not prevail, something wrong here.

IBC Code Reads

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