Honestly, I do NOT have a bathroom obsession. It’s just a coincidence that once again, a code question came up regarding a bathroom door.
You know how sometimes you just know something, and then someone questions you and then you start to question yourself? That’s what happened yesterday. I was creating some hardware sets for a small restaurant project, and I pointed out to the architect that the 2′-8″ wide doors on the single bathrooms weren’t wide enough. I didn’t stop to consider whether I was right or not…I just told him that he needed wider doors.
When he said that he thought they could be 2′-8″ wide because the bathrooms weren’t considered “occupiable space,” I started to wonder if there was an exception I didn’t know about. It made sense…doors to toilet stalls don’t have to provide 32″ clear…why should small individual bathrooms be any different, especially since there was a designated accessible bathroom with a 3′ wide door?
We called in an expert – the code consultant. They are an extremely valuable source of information and if nothing else, you can get them to make the tough decisions. The code consultant for this project confirmed that the bathroom doors needed to provide 32″ clear opening width, even though the bathrooms were very small.
Speaking of small bathrooms, I took this photo in Maine last summer, in a bathroom that has to be the smallest commercial (non-airplane) bathroom I’ve ever been in – only about 12 square feet. As you can tell, my kid thought it was really funny that I was taking a picture of the bathroom, and she still asks me why I did it whenever we go to this restaurant. I knew it would come in handy someday.
The moral of the story…even small bathrooms need big doors. For more information about clear opening width, refer to this post.
You need to login or register to bookmark/favorite this content.
This small restroom is obviously not accessible. Problem is that is looks fairly new, and if it was designed and constructed for first occupancy after January 26, 1992, or renovated after that date, it must comply with the design requirements for “new construction” under the ADA Accessibility Guidelines for Buildings and Facilities (ADAAG). What most people don’t realize, this means that ALL toilet rooms must be accessible.
Whenever someone claims that a restroom doesn’t need to be accessible because there is another “designated” accessible bathroom elsewhere, I cringe. It is a misunderstanding of the Guidelines to believe that a certain number of toilet rooms need to be accessible, and the others do not.
Justification often includes the idea that these other non-accessible bathrooms will only be used by employees or some other group, or that they are not “public” toilet rooms. The fact is, ALL toilet rooms, regardless of who uses them and regardless of how many other “accessible” toilet rooms are available, must be fully ADA compliant if constructed or renovated after January 26, 1992.
Furthermore, if one is altering an area, room or space that contains a primary function, all of the toilet rooms serving the altered area must be brought into compliance. The only limitation here is that one can’t be compelled to spend more than 20% of the cost of the original cost of alterations to the primary function area on “path of travel” obligations like restrooms.
Only two other exceptions come to mind: a private restroom (that is, a restroom used by only one individual and accessed through a private office, like the owners private restroom), is allowed to be “adaptable”. This means it must be pretty much accessible except that a few elements are permitted to be non-compliant because they can be easily modified down the road and made accessible (for example, the entry door can swing into the clear floor space of a required accessible fixture; the toilet seat is not required to be at the accessible height; the lavatory is not required to have knee and toe clearances; grab bars are not required at water closets or on bathtubs/showers, however adequate blocking must be installed behind the wall to accommodate them in the future).
The other exception is for a building predating the ADA (designed and constructed before 1992), which has not been and is not being altered. In this case, the ADA still requires that equal access be provided to persons with disabilities to all the programs, services, activities and facilities offered to others in general, but at what point a building owner has provided “equal” access (in other words, persons with disabilities would not be discriminated against) is subjective. Bottom line then is that in the case of older buildings that are not being renovated, the owner would only need to renovate restrooms until equal access to restroom facilities for persons of all abilities is achieved.
Kenneth Otten
ADA Expert
Thanks for your insightful comment, Ken! You’re right – this tiny bathroom is definitely not accessible. The sad part is that this is a popular restaurant with two bathrooms this size and a very narrow hallway leading to them. As far as I know there is no other bathroom in the restaurant so even if it was built before 1992, there is no way for the restaurant to provide equal access.