Important Information About ADA Requirements For Bathing Rooms

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Many truckstop and travel plaza owners have questions about the bathing rooms, also called shower rooms, at their locations. The requirements under the Americans with Disabilities Act (ADA) regarding bathing rooms are not new. They were first required in the 1991 ADA Standards but they have been misinterpreted for the past 20 years.

A bathing room is specifically defined in the ADA Standards as containing one shower or one shower and one bathtub, one lavatory and one water closet. Each of these items must be compliant with the ADA Standards. Below is a summary of the requirements, but is in no way a comprehensive list of the Standards for bathing rooms. Please refer to the 2010 ADA Standards for Accessible Design for a full list or discuss your specific needs with an expert.

Operators often ask how many bathing rooms must be accessible. Section 213.2 of the ADA Standards states, “Where bathing rooms are provided, each bathing room shall comply.” This means each individual bathing room must comply. This same section lists exceptions, but don’t misinterpret these, there are no exceptions for the bathing room statement “each shall comply.”

Section 603 is important regarding requirements for bathing rooms. This section covers clearances, mirrors, coat hooks and shelves. Below are some of the main areas to pay attention to.

  • Clearances:
    • Turning space
      • Circular turning space of 60-inches diameter minimum or T-shaped space
      • Required clear floor spaces, clearance at fixtures and turning space shall be permitted to overlap
  • Door swing:
    • Doors shouldn’t swing into the clear floor space or clearance required for any fixture
    • Doors can swing into the required turning space
  • Mirrors:
    • Mirrors located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 40-inches maximum above the finish floor or ground
    • Mirrors not located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 35-inches maximum above the finish floor or ground
  • Coat hooks and shelves:
    • Coat hooks should be located no higher than 48 inches and no lower than 15 inches
    • Shelves shall be located no higher than 48 inches and no lower than 40 inches 

Water closets are discussed in section 604. Below are some of the requirements for water closets.

  • Water closet shall be positioned with a wall or partition to the rear and to one side
  • Centerline of water closet shall be 16 to 18 inches from the side wall or partition
  • Clearance around a water closet shall be 60-inches minimum measured from the side wall and 56-inches minimum measured perpendicular from the rear wall
  • Seat height of a water closet above the finish floor shall be 17 to 19 inches measured to the top of the seat

Section 606 covers the requirements for lavatories and sinks. The clear floor space or ground space shall be 30-inches by 48-inches minimum. The graphic helps illustrate knee and toe clearance requirements. Operators can also reference section 306 of the ADA Standards for these requirements.

Shower compartments are covered in Section 608 of the 2010 ADA Standards, and a variety of shower types are describe in this section. Below are some of the requirements for the standard roll-in type shower.

  • Standard roll-in type shower:
    • Roll-in type shower compartments shall be 30-inches wide minimum by 60-inches deep minimum
    • The entry on the face of the shower compartment should be a minimum of 60 inches
    • A clearance of 30-inches wide by 60-inches long minimum shall be provided adjacent to the open face of the shower compartment 

Be sure the grab bars within the shower compartment comply with Section 609. Below are the requirements for grab bars within the standard roll-in type shower.

  • Grab bars for standard roll-in type showers:
    • Where a seat is provided, grab bars shall be on the back wall and the side wall opposite the seat. Grab bars shall not be provided above the seat
    • Where a seat is not provided, grab bars shall be provided on three walls
    • Grab bars shall be installed six-inches maximum from adjacent wall

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The photo of the left shows what The McIntosh Group accessibility surveyors have typically seen while conducting audits of bathing rooms. There are several barriers shown in the photo. These barriers are listed below along with the corresponding section from the 2010 ADA Standards for Accessible Design.

  • o Grab bars should not be provided above the seat. (608.3.2)
  • o The threshold is higher than the required 1/2-inch maximum for roll-in type shower compartments. (608.7)
  • o The spacing between the grab bar and projecting objects above is less than the required 12-inch minimum. (609.3)
  • o The L-shaped seat is backwards. The edge of the seat closest to the back shower wall should be the wider portion, as shown in the photo of a correctly installed L-shaped seat. (610.3.2)

The photo on the right shows the correct orientation for an L-shaped shower seat. Notice that the wider portion is closest to the back shower wall.

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This is a brief overview of the requirements for bathing rooms. The main area of focus is that each bathing room must comply. Refer to the 2010 ADA Standards for Accessible Design for a full list of the Standards or discuss your specific needs with an ADA expert.

/// Bradley Gaskins is the principal and chief operating officer of The McIntosh Group. He has more than 25 years experience in the practice of architecture and a specific expertise in the American with Disabilities Act and national building codes. Gaskins blogs monthly on NATSO's blog about ADA requirements for truckstops. Visit http://www.natso.com/blog/category/american-disabilities-act to read recent articles.

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This article originally ran in Stop Watch magazineStop Watch provides in-depth content to assist NATSO members in improving their travel plaza business operations.

The magazine is mailed to NATSO members bimonthly. If you are a member and not receiving Stop Watchsubmit a request to be added to the mailing list. Not a memberJoin today or submit a request to receive additional information.

Brad Gaskins, AIA, CASp's photo

Brad Gaskins, AIA, CASp

Brad has more than 25 years experience in the practice of architecture and a comprehensive understanding of professional practice nationwide. Brad brings a unique and valuable perspective to The McIntosh Group’s practice and clients, with a specific expertise in the Americans with Disabilities Act (ADA) and national building codes. Brad has gained recognition as an expert witness for clients with ADA compliance complaints. He represents NACS, The Association for Convenience and Fuel Retailing, as a full voting member on the International Code Council (ICC), American National Standards Institute (ANSI) A117.1, Consensus Committee on Accessible and Usable Buildings and Facilities. His objective is to share, with the committee for their deliberations, the potential impact of the standards on the convenience store and truckstop industry. Brad has an undergraduate degree in engineering and a master’s degree in architecture from the University of Oklahoma. He is currently serving as president of AIA Oklahoma.More
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