U.S. Access Board - Chapter 6: Toilet Rooms (2023)

This guide explains requirements in the ADA Standards fortoilet rooms.

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Required Compliance

[§213]

Plumbing and building codes address the number and type of toilet roomsand toilet fixtures required for a facility. The ADA Standards, on theother hand, do not address the number of toilet rooms or fixturesrequired for a facility, but instead specify which ones must beaccessible where provided. In new construction, access is required toall toilet rooms, including those for employees. However, where singleuser toilet rooms are clustered in one location, at least half for eachuse must comply (§213.2., Ex. 4). In the case of single user portableunits, access is required to at least 5% at each cluster, excludingthose on construction sites for construction personnel which are fullyexempt (§213.2, Ex. 3, §203.2).

Clustered Single User Toilet Rooms

Clustered single user toilet rooms (2 minimum) are those that are nextto, or close to, one another. No more than 50% for each use within acluster must comply. Compliant toilet rooms and portable units must belabeled by the International Symbol of Accessibility unless all areaccessible (§213.2, Ex. 3, §216.8).

Unisex (Single-Use or Family) Toilet Rooms

[§213.2]

Where multi-user toilet rooms are provided, accessibleunisex toilet rooms cannot serve as a substitute for access tomulti-user rooms, except in alterations where making multi-user roomscomply is not technically feasible (§213.2, Ex. 1). Otherwise, wheremulti-user and unisex restrooms are provided, both types must comply.Providing an accessible unisex toilet room in addition to multi-usertoilet rooms is helpful for those who use personal care assistants ofthe opposite sex. The International Building Code (IBC) requiresaccessible unisex or "family" toilet rooms in assembly and mercantileoccupancies where a total of six or more toilet fixtures isrequired (§1108.2.1 in the 2000 IBC and §1109.2.1 in later editions).The ADA Standards require that unisex toilet rooms, where provided, haveprivacy latches and contain at most one lavatory, one water closet, andone urinal (or a second water closet) (§213.2.1).

Medical Care and Long-Term Care Facilities

[§223.1]

In licensed medical care and long-term care facilities,toilet rooms that are part of accessible patient or resident sleepingrooms, excluding critical or intensive care patient sleeping rooms, mustcomply (§223.1, Ex., §805.4). The Standards cover independentaccessibility and do not address design for use that is assisted bymedical or resident care personnel. Features for assisted use thatconflict with the Standards can be provided in those toilet roomsserving rooms not required to comply with the Standards. Otherwise anydeparture from the Standards must be based on the provision for“equivalent facilitation” (§103) which permits alternatives tospecified requirements that provide substantially equivalent or greateraccessibility and usability. This means that the alternative solution isjust as, if not more, effective than what is required by the Standardsin terms of accessibility, usability, convenience, and reliability forpeople with disabilities.

Additions

[§202.2]

Additions are required to comply with requirements in the Standards fornew construction. Each toilet room of an addition must comply as wouldbe required in new construction.

Alterations

[§202.3]

When existing toilet rooms are altered, the Standards apply according tothe planned scope of work. If one toilet room on a floor is altered, theStandards apply to that room only; if all toilet rooms on a floor arealtered, the Standards apply to each toilet room that would be requiredto comply in new construction. The scope of work also determines whichtechnical requirements apply. If some, but not all, elements in a toiletroom are altered, only those elements altered must comply. If a room orspace is completely altered (or built new as part of an alteration), theentire room or space must comply.

In a project involving alterations to the toilet, grab bars, faucet controls, and mirror in a restroom, the Standards apply to these elements but not to those that remain unaltered. In more extensive projects where additional elements are altered, application of the Standards is greater, commensurate with the scope of work.

Compliance in an alteration is not required where it is "technicallyinfeasible." The term is defined as "something that has littlelikelihood of being accomplished because existing structural conditionswould require removing or altering a load-bearing member that is anessential part of the structural frame; or because other existingphysical or site constraints prohibit modification or addition ofelements, spaces, or features that are in full and strict compliancewith the minimum requirements." For example, combining two toiletcompartments to create an accessible compartment may be technicallyinfeasible where it would reduce the fixture count below the numberrequired by the applicable plumbing code.

When it is technically infeasible to make existing men's and women'srooms comply, an accessible unisex toilet room can be provided insteadif it is in the same area and on the same floor as the existing toiletrooms (§213.2, Ex. 1). Where technical infeasibility is encountered,compliance is still required to the maximum extent feasible.

Alterations and Additions to Primary Function Areas

[§202.4]

When an area containing a primary function (a major activity intendedfor a facility) is altered or added to a facility, an "accessible pathof travel" is required. The accessible path of travel, which mustextend from site arrival points to the primary function area, includesprovided restrooms (at least one for each sex or, if only unisexrestrooms are provided, at least one unisex restroom), telephones, anddrinking fountains, where provided, that serve the primary functionarea. The accessible path of travel is required to the extent that itdoes not cost more than 20% of the total cost of the work to the primaryfunction area. Compliance is required up to the point this cost cap isreached, even where it does not result in a fully accessible path oftravel. See the Alterations and Additions Guide.

Alterations to Qualified Historic Facilities

[§202.5]

The Standards provide certain exceptions for qualified historicfacilities where compliance in an alteration would threaten or destroythe historic integrity or significance of a facility as determined bythe appropriate State Historic Preservation Official or Advisory Councilon Historic Preservation. One of these exceptions allows access to beprovided to a unisex toilet room or to one men's and one women's roomregardless of the number of toilet rooms altered or added (§213.2, Ex.2).

This guide notes some provisions in the International Building Code (IBC) and the ICC A117.1 Standards for Accessible and Usable Buildings and Facilities that are not found in the ADA Standards. For example, the A117.1 standard, which provides technical provisions and is referenced by the IBC, requires a vertical grab bar at water closets. Not all differences between the ADA Standards and editions of the IBC and A117.1 standard are noted in this guide.

Components of Accessible Single User Toilet Room

Requirements in the Standards for toilet rooms address doors, turningspace, plumbing fixtures, mirrors, dispensers, shelves, and otherelements provided.Other provisions in the Standards also apply.

Urinals (§213.3.3)

Water Closets

[§213.3.2, §604]

Criteria for water closets address location, clearance, seats, grabbars, flush controls, and dispensers. Water closets can be arranged foreither a left-hand or right-hand approach.

Location, Clearance, Seat Height and Flush Controls

Grab Bars

[§604.5]

Grab bars are required to be mounted on the walls beside and behind thewater closet. They can be separate or continuous. When returned towalls, the length is measured to the centerline of the return,consistent with industry practice. When attached at other points alongthe bar, the length is measured to the end of the bar.

Grab bars and wall or other surfaces adjacent to them must be free ofabrasive or sharp elements. Any projecting object must be located atleast 12″ above grab bars and at least 1½″ from the bottom and ends ofgrab bars so that the reach and use of grab bars is not impeded.

Minimum Clearances at Grab Bars

Grab bars can have circular or non-circular cross-sections but must haverounded edges. The 1½″ clearance between the grab bar and wall is not aminimum but an absolute dimension to prevent entrapment. Grab barscannot rotate within fittings. The structural strength of grab bars mustwithstand a vertical or horizontal force of 250 lbs. at any point on thegrab bar, fastener, mounting device, or supporting structure.

Cross Section and Clearance

The Standards do not require or address additional folding or swing-awaygrab bars on the open side of the water closet. However, if provided,they must be mounted so that they do not interfere with use of therequired grab bars or the clear floor space at water closets. Also, itis important they are properly secured (although this is not addressedby the Standards).

Toilet Paper Dispensers

[§604.7]

Recessed Dispenser Location

Non-Recessed Dispenser Location

If the grab bar is 36″ high, a non-recessed toilet paper dispenserlocated above the bar must have an outlet at exactly 48″ high toaccommodate both the maximum reach height and the 12″ minimum clearance abovethe grab bar.

Example Single User Toilet Room

The Standards do not directly specify the size of toilet rooms which isdetermined by a variety of factors, including the layout and number offixtures, the presence of other features, such as baby changing tables,and even the swing of doors. How various space requirements are met alsodetermine the minimum room size, including required clearances atfixtures and other elements, turning space, and door maneuveringclearance.

Accessible toilet rooms can be configured in many different ways. Thelayout shown here is used only as an example in illustrating thefeatures of a compliant toilet room. These designs show the minimumdimensions specified in the Standards. Providing additional space intoilet rooms will enhance usability.

Option: Recessed Lavatory

Doors

[§404]

Maneuvering clearance is required at doors based on the approach andswing. No elements can overlap door maneuvering clearances.

Doors can swing into fixture clearances in single-user toilet roomswhere unobstructed wheelchair space is available beyond the door swing(603.2.3). This provides space to enter the room and clear the doorusing wheeled mobility aids.

Turning Space

[§304]

Turning space is required in the room and can be provided as a 60″diameter circle or T-shaped space. Doors can swing into the turningspace. The orientation of the T-shaped space is not specified, and itcan be located for approach at any segment (i.e., the stem or eitherarm).

Elements with knee and toe clearance can overlap a portion of theturning space. With t-shaped space, overlap is limited to one segment ofthe “T” so that the other two remain clear for approach and backing up.

Approximate Room Dimensions

With a water closet and lavatory side-by-side, the plumbing wall istypically determined by the width of the water closet clearance, thelavatory fixture width, plus any additional lavatory clearance beyondthe fixture (unless the lavatory is recessed). Other elements provided,such as a baby changing table, may increase this dimension.

In the same example, if the door is opposite the plumbing wall andswings in, the room depth will likely be determined by keeping the doorswing outside fixture clearances (left). Alternatively, if there isunobstructed wheelchair space beyond the door swing, the doormaneuvering clearance and the horizontal depth of the lavatory maydetermine the room depth (right). Turning space is typically availablein the room without further increase in room size where doors swing in.

Note: Other elements provided may increase minimum room dimensions.

If the door swings out, the room depth is usually determined by thedoor maneuvering clearance and the horizontal depth of the lavatory.Turning space usually can be provided without further increase in thisdesign but providing additional depth will help minimize fixture overlapof the turning space for improved access.

Note: Other elements provided may increase minimum room dimensions.

Example: Lavatory Opposite Water Closet

Toilet rooms can be configured in many different ways, but the samerequirements apply, including those for fixtures, doors, and turningspace. This example shows a door swing located outside fixtureclearances (obviating the need for wheelchair space beyond the arc ofthe door swing) and turning space free of any overlapping elements(left). Fixtures and other elements can overlap turning space but notthe door maneuvering clearance (right).

Dispensers and Receptacles [§205, §309], Coat Hooks and Shelves [§213.3.7, §603.4]

[§205]

Dispensers, receptacles, and other operable parts, as well as shelvesand coat hooks, must comply where provided.

Baby Changing Tables

[§226]

Where baby changing tables are provided, they must complyas a work surface and, if they project into circulation paths, asprotruding objects.

Private Toilet Rooms Accessed through a Private Office

Single-occupant toilet rooms accessed only through a private office andnot for common or public use are permitted exceptions that allow certainaccess features, such as grab bars, to be provided after construction asneeded. However, they still must be sized for accessibility and fullymeet all space requirements. Enlarging or reconfiguring a private toiletroom is not permitted by the Standards as a post-constructionaccommodation.

Exceptions for Private Toilet Rooms

Note: All other applicable requirements, including clearances and turning space, must be met.

Water Closets in Residential Dwelling Units

In residential dwelling units required to be mobility accessible, atleast one bathroom must comply (§809.4). Accessible water closets indwelling units are permitted several exceptions that allow somefeatures, such as grab bars and knee and toe space below lavatories, tobe provided after construction as needed if certain conditions are met.In addition, lavatories can overlap a portion of the water closetclearance if additional clearance depth is provided.

Exceptions for Water Closets in Dwelling Units

Note: All other applicable requirements, including clearances and turning space, must be met.

Dwelling Unit Water Closet and Lavatory

Water Closets and Toilet Compartments for Children’s Use

[§604.1]

Specifications based on children's dimensions can be followed whenwater closets and toilet compartments are designed primarily for use bychildren ages 12 and younger. Structured as exceptions, these provisionsare optional and serve as alternatives to adult-based dimensions. Underthe Standards, the decision to design a toilet room for children is leftto other building requirements or regulations, good practice, clientpreference, or other factors. When a toilet room or compartment isdesigned for children, all pertinent alternate specifications fortoilets, compartments, grab bars, and dispensers must be applied.

The Standards provide non-mandatory guidance on specifications accordingto the age group served that reflect the differences in size, stature,and reach ranges of children ages 3 through 12. The chosenspecifications should correspond to the primary user group and beconsistent within an age bracket. If the planned user group spans morethan one age group, one can select specifications that align on theborderline between the two groups.

Water Closet for Children 12 and Younger

Note: All other requirements for children's water closets and toiletcompartments are consistent with those based on adult dimensions.

The rear grab bar can be shifted to the open side of the water closet orsplit where it would conflict with the location of flush controlsrequired by the applicable code (§604.5.2, Ex. 2).

Portable Toilet Units

Where portable single user toilet units are provided, including attemporary events, access is required to at least 5% in each cluster(213.2, Ex. 3). Compliant units must be labeled by the InternationalSymbol of Accessibility (ISA). Portable units must meet all requirementsfor toilet rooms that apply, including fixture clearances, turningspace, and door maneuvering clearances.

Multi-User Toilet Rooms

The Standards address toilet compartments and urinals which apply inaddition to criteria for toilets, lavatories, mirrors, dispensers,shelves, and other elements provided.

Components of Multi-User Toilet Rooms

Wheelchair Accessible Toilet Compartments

[§213.3.1]

At least one toilet compartment must be wheelchair accessible wheretoilet compartments are provided.

Compartment doors must be offset from the water closet in either thefront or the side partition so that there is space to enter thecompartment. Doors can be hinged on the left or right side of theopening.

Compartment Doors

[§404]

Compartment doors must meet applicable requirements for doors, includingthe clear width (32″ minimum), hardware, and opening force (5 lbs. maximum).

Compartment doors must meet maneuvering clearance requirements, but areduced clearance is specified for compartment doors providing a latchapproach. Doors can be hinged on either side.

The required size of compartments provides the minimum space needed toenter, approach and transfer to water closets, and exit. As with waterclosets generally, the only elements that can overlap the minimumcompartment/water closet clearance are: the water closet, associatedgrab bars, dispensers, coat hooks, shelves, and sanitary napkin disposalunits. Other elements and fixtures, including baby changing tables inthe stowed position, cannot overlap this clearance. If an additionalplumbing fixture, such as a lavatory, is provided in a compartment, thecompartment must meet the requirements for single-user toilet rooms in§603.

Toilet compartments are typically enclosed by partitions. Full-heightpartitions and door assemblies are not prohibited but will require alarger compartment because toe clearance below partitions is notavailable.

Compartment with Toe Clearance Below Partitions

Toilet Compartments Designed for Children’s Use

[§604.8.1]

End-of-Row Toilet Compartment

Wheelchair accessible toilet compartments located at the end of the rowcan provide more room by incorporating dead-end aisle space. The doorcan swing in if it clears the minimum compartment area. The compartmentdoor can be located in the side partition that is closer to the watercloset when the door opening is beyond the minimum depth of thecompartment area.

Toilet Compartment with a Lavatory

[§603]

No other fixture besides the toilet can be located in the minimum spacerequired for the compartment. If a lavatory or another plumbing fixtureis located in a compartment, the compartment must meet requirements fortoilet rooms, including turning space. Another compliant lavatory isrequired outside the compartment.

Ambulatory Accessible Toilet Compartment

[§213.3.1]

Ambulatory accessible toilet compartments provide parallel grab bars andbenefit people who use crutches, canes, walkers and similar devices orwho need support in sitting or standing. They do not accommodatewheelchairs or scooters and are required in addition to the wheelchairaccessible compartment in toilet rooms with six or more toiletcompartments or where the combined total of toilets and urinals is sixor more. They are sized so that both grab bars are within reach. Grabbars must meet specifications for size, location, and securement.

Urinals

[§213.3.3]

At least one urinal must comply where two or more urinals are providedin a toilet room. Specifications address rim height, depth, flushcontrols, and clear floor space. Accessible urinals must be either wallhung or stall type. Flush controls must be automatic or, if handoperated, compliant as operable parts and located within accessiblereach range (§309).

Clear floor space for a forward approach is required. Partitions orprivacy panels cannot obstruct or reduce the minimum clearance. Ifpartitions or panels obstruct both sides of the clear floor space formore than 24″, the clear floor space must be at least 36″ wide insteadof 30″ wide.

Common Questions

Toilet Rooms

Are toilet rooms that serve employees but not the public required to comply?

Yes. Public and common use toilet rooms, including those usedexclusively by employees, must comply. Private toilet rooms for a singleoccupant accessed only through a private office are permitted limitedexceptions for certain access features, such as the later installationof grab bars if walls have blocking or are reinforced.

Can access be provided to a unisex restroom instead of to men’s and women’s rooms?

If men’s and women’s rooms are provided, they must be accessible evenif a unisex toilet room is also provided. However, in alterations whenit is technically infeasible to make existing men’s and women’s roomscomply, an accessible unisex toilet room can be provided instead if itis located on the same floor and in the same area as the men’s and women’s rooms (§213.2, Ex. 1).

Is access required to a unisex family or gender-neutral toilet room that is provided in addition to accessible men’s and women’s rooms?

Yes. Unisex toilet rooms must be accessible, including where they areprovided in addition to multi-user toilet rooms. Where multiplesingle-user toilet rooms are clustered at one location, no more thanhalf for each use are required to comply (§213.2, Ex. 4).

How does the exception for clustered single user toilet rooms of the same type (no more than 50% at each cluster) apply when there is an odd number of toilet rooms?

When there is an odd number of single user toilet rooms of the same typein a cluster, the number of accessible toilet rooms can be rounded up ordown. Rounding up is recommended for better access and is otherwiserequired when fractions or remainders result in determining the numberof facilities or elements required to comply (§104.2). However, roundingdown is permitted in this instance because the exception for clusteredsingle user toilet rooms states that “no more than 50 percent of thesingle user toilet rooms for each use at each cluster shall be requiredto comply” (§213.2, Ex. 4).

Is there a maximum distance or separation that applies to toilet rooms within the same cluster?

No maximum distance is specified, but clustered single user toilet roomsare those that are next to, or close to, one another.

What is the impact of providing two unisex toilet rooms instead of a designated single-user men’s room and a designated single-user women’s room?

If two unisex restrooms of the same type are clustered in one location,only one of the two is required to comply under the Standards (§213.2).If a single-user men's room and a single-user women's room areprovided, both must comply even if clustered since they are differenttypes.

Can toilet rooms be designed for assisted instead of independent access?

The Standards address independent accessibility and do not containrequirements for spaces and elements designed for assisted use. Inmedical care facilities, features for assisted use that conflict withthe Standards can be provided in those toilet or bathing rooms servingpatient bedrooms that are not required to comply with the Standards.Otherwise, any departure from the Standards, including those related toassisted use, must be based on the provision for "equivalentfacilitation" (§103) which permits alternatives to specifiedrequirements that provide substantially equivalent or greateraccessibility and usability.

In facilities that are exempt from the requirement for vertical access between stories, are toilet rooms required to comply on stories not connected by an accessible route?

Yes. In facilities that are not required to provide an accessible routebetween stories based on the story count or square footage per floor(§206.2.3, Ex. 1 or 2), all other provisions in the Standards, includingthose for toilet rooms, still apply to levels and stories not connectedby an accessible route. In addition, if a toilet room is provided on aninaccessible story of such a facility, a toilet room also must beprovided on an accessible story so that it is connected to an accessibleentrance by an accessible route (§213.1).

What is the minimum size of toilet rooms?

The standards do not specify the minimum size of toilet rooms. Therequired size of a toilet room is determined by room layout, the numberand configuration of fixtures provided, required clearances, thepresence of baby changing tables and other amenities, turning space,door maneuvering clearances, and other factors and requirements.

Can doors swing into the turning space and fixture clearances?

Doors can swing into the turning space. They cannot swing into theclearance required at plumbing fixtures, except in single user toiletrooms where clear floor space 30″ minimum by 48″ minimum is providedin the room beyond the arc of the door swing (§603.2.3, Ex. 2). Inaddition, doors can swing into fixture clearances at single-occupanttoilet rooms accessed only through a private office and not for commonuse if the swing of the door can be reversed (§603.2.3, Ex. 1).

When is a toilet room required to be designed for children?

The Standards do not require that toilet rooms be designed for children.This determination is usually made based on other building requirementsor regulations, good practice, or client preference. However, theStandards do provide alternate specifications based on children'sdimensions that can be followed where a toilet room is designed forchildren.

If a restroom serves both adults and children, must an accessible toilet compartment be provided for both adults and children?

In restrooms that serve both adults and children, it is advisable, butnot required, to provide wheelchair accessible toilet compartments forboth user groups, but the Standards require only one wheelchairaccessible toilet compartment in all toilet rooms.

Can elements with knee and toe space overlap the required turning space?

Yes. Elements that provide compliant knee and toe space, such aslavatories, can overlap a portion of the turning space.

Can elements with knee and toe space overlap the door maneuvering clearance?

Grab bars and other elements cannot overlap the door maneuvering clearance but can be located within the 8 inches maximum offset from the face of the door.

No. Elements, including those providing knee and toe space, cannotoverlap or protrude into the maneuvering clearance required at doors anddoorways. However, door maneuvering clearances can be offset up to 8″from the face of the door to accommodate wall thickness, casework,shelves, or other elements adjacent to doorways, including grab bars.The door maneuvering clearance must be measured from the leading edge ofsuch elements so that the full clearance is free of any obstruction.

Must toilet rooms be identified by the International Symbol of Accessibility (ISA)

Labeling accessible toilet rooms with the ISA is required only whereinaccessible toilet rooms are present. For example, half of single usertoilet rooms of the same type in each cluster (5% in the case ofportable units) are required to comply, and those that are accessiblemust be identified by the ISA unless all are accessible (§213.2, Ex. 4,§216.8). In alterations where existing toilet rooms do not comply,directional signs with the ISA must be provided to indicate the locationof the nearest accessible toilet room which must be labeled by the ISA.

Do the Standards require restroom pictograms?

No. The ISA is the only pictogram the Standards require in labelingtoilet rooms. Other codes or regulations may require pictograms toidentify men's and women's rooms and unisex restrooms. The Standardsrequire that pictograms labeling permanent rooms and spaces, includingtoilet rooms, be on a field at least 6″ high and include the verbalequivalent in raised characters and braille below the pictogram.Informational pictograms, such as the ISA, are not subject to therequirements for field height or verbal text.

Do the Standards require accessible toilet compartments, including the ambulatory accessible compartment, to be labeled by the ISA?

No. The Standards do not require toilet compartments to be identified bythe ISA.

Water Closets

Can an adjacent lavatory overlap the water closet clearance?

No. Lavatories are not permitted to overlap the 60″ wide minimum spaceat water closets, except in residential dwelling units if the watercloset clearance is 66″ deep minimum (§604.3.2, Ex.). Lavatories (or otherplumbing fixtures) can be adjacent to the water closet if recessed so asnot to overlap the water closet clearance. (The rear grab bar can be24″ long in this instance if there is not sufficient wall space for a36″ grab bar.)

Can other elements overlap the water closet clearance?

The only elements beside the water closet that can overlap the watercloset clearance are: associated grab bars, dispensers, coat hooks,shelves, and sanitary napkin disposal units (§604.3.2). No otherelements can overlap the water closet clearance.

Can the toilet paper dispenser be mounted above the side grab bar?

Toilet paper dispensers can be mounted above the side grab bar if theydo not protrude into the 12 inches high minimum clearance above the bar andthe outlet is within the maximum 48 inches height. With large rolldispensers, ensuring that the outlet is within the height limit can bedifficult when mounted above bars unless they are recessed.

How is the distance from the water closet measured for toilet paper dispensers with large or multiple rolls?

The required distance of toilet paper dispensers from the front of thewater closet (7″ to 9″) is measured to the centerline of thedispenser, including large-roll and multiple-roll dispensers.

How can conflicts between the rear grab bar and the required location of flush controls be resolved?

If plumbing codes require a flush control location that conflicts withthe rear grab bar, the grab bar may be split or shifted to the openside. This is permitted only where applicable codes mandate flushcontrols in such a location.

Are automatic (motion sensor) flush controls required to be on the open side of the water closet?

No. Motion activated flush controls are not required to be on the openside of the water closet. If a water closet has a manual flush controlin addition to a motion activated one, it is recommended, but notrequired, that the manual control be located on the open side of thewater closet. Manual flush controls, even those intended for custodianuse, are helpful at water closets and urinals when the motion sensorfails to activate.

Are flush controls located on valves, walls, or tanks that are centered on the fixture compliant (i.e., on the open side)?

Manual flush controls, including push buttons, must be usable from apoint between the centerline and the open side of the fixture. A portionof the control can be outside the range if it is usable without havingto reach beyond the water closet centerline from the open side.

Can the side and rear grab bars be continuous?

Yes. The rear and side grab bar can be continuous or separate, but ineither case must comply with the specified length and placement.

Must the side and rear grab bar both be at the same height within the specified 33″ to 36″ range?

The Standards do not require both grab bars at the water closet to be atthe same height, although this is advisable. (Horizontal grab bars atshowers must be at the same height.)

Can the side grab bar be located on a half wall or wing wall?

Grab bars, if properly secured, can be mounted on a half wall or wingwall where sufficient wall surface above the grab bar is available. Wallsurface above grab bars provides support and helps prevent arms fromslipping off the bar. Wall surface that extends the full height of therequired 12″ clearance above grab bars, or preferably to the standardadult shoulder height for standees, should provide sufficient support inusing grab bars.

Can the side grab bar be mounted on blocking when the centerline of the water closet exceeds the 18″ maximum?

In new construction, the wall should be furred out so that the watercloset centerline is within the required 16″ to 18″ distance from theside wall. In addressing access to existing water closets that are toofar from the side wall, the side grab bar can be mounted on blocking butit is important that the blocking extend at least 12″ above the grabbar so that adequate wall support is available when using the grab bar.

Can grab bar attachments be located at points along the bar instead of at the ends?

Yes. Grab bar attachments can be at points other than the ends of grabbars.

How is the length of grab bars measured?

Grab bar length is measured to the centerline of the return, consistentwith industry convention. This also applies to post-mounted grab bars.When attached at points other than the ends (e.g., “European” stylegrab bars), the length is measured to the end of the bar.

Can grab bars be mounted to the floor instead of the wall?

No. The Standards require grab bars at water closets on the side andrear wall (§604.5). Grab bars that are floor-mounted obstruct usableclear floor space at the water closet and may be difficult to secure.

Must grab bars have a peened or other textured surface?

No. The Standards do not require grab bars to have peened or texturedsurfaces.

Are folding or swing-away grab bars permitted on the open side of water closets?

Folding or swing-away grab bars are not prohibited by the Standards solong as they do not obstruct use of the required grab bars. It isimportant that they are properly secured.

Is a vertical grab bar required by the Standards?

No. The ADA Standards do not require a vertical grab bar at waterclosets. However, the ICC A117.1 standard, which is referenced by theInternational Building Code, requires an 18″ minimum vertical grab baron the side wall above the horizontal grab bar for people who areambulatory. This grab bar can be located within the 12″ minimumclearance required above the horizontal grab bar.

Can grab bars have infill plates to prevent suicide or security risks in detention and correctional facilities?

In detention and correctional facilities, grab bars must fully comply atwater closets serving accessible cells. Infill plates and otheranti-ligature measures may be provided in detention and correctionalfacilities and other facilities so long as they do not impede grippingsurfaces. Grab bars are not required in those cells that are speciallydesigned without protrusions for suicide prevention (§604.5, Ex. 3).

Toilet Compartments

What distinguishes “toilet compartments” from single-user “toilet rooms”?

In some cases, it may be unclear whether water closets enclosed by fullheight partitions are to be treated as toilet compartments orsingle-user toilet rooms under the Standards. Toilet compartments canhave full-height partitions. The determination typically is based onwhether the toilet compartment is located within a restroom/ bathingfacility or if it is entered directly from a common use corridor orexterior route. Those located within a room (such as a men's room,women's room, or gender neutral multi-user restroom, locker room,shower room) can be scoped as toilet compartments under the Standards:at least one wheelchair accessible and, if six or more waterclosets/urinals are provided, at least one ambulatory accessiblecompartment (§213.3.1). Those that directly connect to, or are separatedby, a hallway, corridor, or exterior route, are scoped as single-usertoilet rooms: all must comply except that where clustered, 50% of eachuse must comply (§213.2). If a toilet compartment contains more than oneplumbing fixture (e.g., a lavatory), it must comply as a toilet room(§604.8).

Can compartment door openings be located more than 4″ from the side partition when the compartment width exceeds the 60″ minimum?

The Standards require the door opening to be located 4″ maximum fromthe side partition further from the water closet (or, if located in theside partition, 4″ maximum from the front partition). An increase abovethe 4″ maximum where compartments exceed the 60″ minimum width may notimpact usability if the extra width of the compartment equals or exceedsthe increase above the 4″ maximum (as permitted by the ICC A117.1Standard), but such a departure must be based on the provision ofequivalent facilitation (§103).

Are toilet compartment doors prohibited from swinging into fixture clearances?

Yes. Toilet compartment doors, including those of inaccessiblecompartments, cannot swing into clearances required at lavatories andother plumbing fixtures. In addition, the compartment doors cannot swinginto the minimum required area of wheelchair accessible and ambulatoryaccessible compartments.

Are spring hinges and gravity hinges on compartment doors considered “closers” in determining the size of maneuvering clearances?

No. Some approaches require additional maneuvering clearance when a dooror gate is equipped with a closer because of the additional force thatmust be counteracted in proceeding through doors. Since spring andgravity hinges do not significantly impact maneuvering at doors, theyare not "closers" for purposes of specifying door maneuveringclearance.

Can accessible toilet compartments have full-height walls instead of partition panels?

Yes. But the minimum compartment size (both width and depth) isincreased more than 6″ if minimum toe clearance is not provided belowthe front partition and a side partition. Doors, including full doorassemblies, must be self-closing and meet all applicable requirementsfor doors.

Can pilasters or other partition supports intrude into the required toe clearance below partitions?

Yes. Vertical supports for partitions are permitted within the requiredtoe clearance. The width of supports is not specified or limited by theStandards.

Lavatories and Mirrors

Can a lavatory be located outside of a toilet room?

The Standards do not prohibit location of lavatories outside toiletrooms where permitted by codes and other regulations.

Can a lavatory be provided in a wheelchair accessible toilet compartment?

Yes. But the toilet compartment must meet requirements for toilet rooms,including turning space (§604.8). A second accessible lavatory must beprovided outside the compartment (§213.3.4).

Must the clear floor space at lavatories be centered?

It is advisable, though not required, that the clear floor space benominally centered on the fixture.

Can accessible mirrors be located above lavatories?

Accessible mirrors can be located above lavatories or countertops if thebottom of the reflecting surface is 40″ maximum above the finish floor(§603.3). The bottom of the reflecting surface of mirrors not locatedabove lavatories or countertops must be 35″ maximum above the finishfloor.

If a toilet room has a full-length mirror and a mirror above a countertop or lavatory, must both types comply?

No. The Standards require only one mirror in a toilet room to comply. Ifmirrors are provided above lavatories or counters and at other locationsin a toilet room, it is advisable, but not required, that one of eachtype comply.