Support for Proposed Change to IPC Table 403.1
Minimum Number of Water Closets 

Potential Corrections   (F) = Female  (M) = Male    

CHANGE  1

Current IPC 2009 is A-2  Bar   1 per 40 
  Change A-2  Bar  (F)  1/25 first 25 then 1 per 75 
  Change A-2  Bar  (M) 1/25 first 25 then 1 per 90

Current IPC 2009 is  A-2 Restaurant  1 per 75
   Change A-2 Restaurant  (F)  1/25 first 25 then 1 per 80
   Change A-2 Restaurant  (M) 1/25 first 25 then 1 per 100

Reason: The purpose of the change is to substitute revised material for current provisions of the code. The American Restroom Association (ARA) is often questioned by the public and by reporters doing stories about the problems people face finding proper toilet facilities when away from home. One of the problems relates to having to wait too long for a restaurant toilet to free. To the degree that respondent recall details and also based on informal observation by ARA advocates, when more then 50 people are in a restaurant one will begin to see occasional toilet queuing when only 1 single occupant per sex toilet is available. Above 100, multiple person lines will appear. This problem is addressed in the UPC 2, which requires between 2 & 3 WC per sex between 15 - 150. The IPC 1 requires only 1 WC per sex for A-2 restaurant occupancies between 16-150. This problem is particularly onerous in venues where people handle food. While those with an urgent need to void bowel or bladder will queue, those needing to wash their hands before eating may defer.
The low IPC A-2 minimum is made worse by the typical no-stall implementation of a single WC toilet. Unlike multi-stalled toilets, single WC toilets are typically user locked and the WC is not available to the next patron until the toilet door is unlocked. While studies such as the APSE Cohen reports 3,4 have shown that the average user typically needs less then 2 minutes to use a WC, there appears to be no studies of the impact of single WC, user lockable toilets. Information is available, however, via the logs generated by automated public toilets (APT). Every American municipality, that has installed single occupant APT’s has found that for legitimate reasons (wheel chair, express breast milk, change colostomy bag, absorbent pads or a child's diaper) user occasionally have a legitimate need to be in the toilet for at least 15 minutes and one city now allows more then 20 minutes before a misuse alarm sounds. This same 'occasional long use' problem occurs in buildings with user lockable toilets and the problem is exacerbated because these lockable toilets also facilitate activities not related to sanitation.    A-2 Pubs and Lounges suffers the same 1 locked toilet at lower occupancies but the attempt to address the problem by requiring 1toilet per 40 results in excessive minimums at at higher occupancies. 

Cost Impact: The code change proposal will increase the cost of construction at lower occupancies but may reduce cost for larger occupant loads

Bibliography: 2006 Uniform Plumbing Code Table 4.1 ‘Retail or Wholesale Stores 
Wall Street Journal ‘Bathroom Backlash Arrives on Main Street ‘ July 26, 2005
29CFR1910.141(c)(1)(i) Table J-1
ASPE report 95-01 Cohen 'Queuing theory approach to plumbing design research' 
ASPE report 92-02 Cohen 'Plumbing fixture requirements for office buildings research report' 

 

CHANGE 2

Current 2009 'M' Mercantile is 1 per 500
   Change M (F)  1 per 25 first 50 then 1 per 400
   Change M (M) 1 per 25 first 50 then 1 per 600

Current IPC 2009 'B' Business  is  1 per 25 first 50 then 1 per 50 
    Change B (F)  1 per 25 first 50 then 1 per 50 
    Change B (M) 1 per 25 first 50 then 1 per 100 

 

Reason:The purpose of the change is to substitute revised material for current provisions of the code. The IPC requires 1 WC per sex for mercantile occupancies between 51-1000. The UPC (1) requires between 2 to 6 WC per sex between 51 - 800. Based on an ARA/Wall Street Journal investigation (2), this low IPC minimum has not caused problems because a majority of the public is not aware that they are allowed to use sanitation facilities in small to midsize mercantile establishments. Media awareness campaigns like the Wall Street Journal story and Section 403.5.1 Directional Signs (P34-06/07) will change the public’s awareness.
Unlike multi-stalled toilets, single WC toilets are typically user locked and the WC is not available to the next patron until the toilet door is unlocked. While studies such as the Cohen report (4,5) have shown that the average user typically needs less then 2 minutes to use a WC, there appears to be no studies of the impact of single WC, user lockable toilets. Information is available, however, via the experience of those American cities that have installed automated public toilets (APT). Every municipality has found that for legitimate reasons (wheel chair, express breast milk, change ostomy bag, absorbent pads or a child's diaper) user occasionally have a legitimate need to be in the toilet for at least 15 minutes and at least one city's now allows more then 20 minutes before an alarm sounds. This same 'occasional long use' problem occurs in buildings with user lockable toilets and the problem is exacerbated because these user lockable toilets also accommodate activities not related to sanitation. A retail store with 1000 people will sometimes include more then 15 employees. OHSA requires 2 WC for 16 on site employees (3). It is likely that those 16 employees competing with 984 other occupants does not satisfy the intent of the OSHA requirement.  In the process of reviewing the requirement for M it was noted that if adjusted for gender the increase in toilet fixtures slope for male in B (Business) could be reduced.

Bibliography: 2006 Uniform Plumbing Code Table 4.1 ‘Retail or Wholesale Stores 
Wall Street Journal ‘Bathroom Backlash Arrives on Main Street ‘ July 26, 2005
29CFR1910.141(c)(1)(i) Table J-1
ASPE report 95-01 Cohen 'Queuing theory approach to plumbing design research' 
ASPE report 92-02 Cohen 'Plumbing fixture requirements for office buildings research report' 

Cost Impact: The code change proposal will increase the cost of construction at lower occupancies but may reduce cost for larger occupant loads

 

CHANGE 3

403.2 Separate facilities. Where plumbing fixtures are required, separate facilities shall be provided for each sex. Exceptions:
1. Separate facilities shall not be required for dwelling units and sleeping units.
2. Separate facilities shall not be required in structures or tenant spaces with a total occupant load, including both employees and customers, of 15 or less.
3. Separate facilities shall not be required in mercantile occupancies in which the maximum occupant load is 50 or less.

ADD 

4.  Two unisex toilets can be substituted where the minimum number of required water closets from Table 403.1 is one (1) for each sex.

Justification:  Unisex toilets provide inherent potty parity.  Two unisex toilets increase overall availability.  A single gender based toilet can be unavailable for periods of up to 15 minutes when, for example,  the current occupant is using it for companion care, to change diapers, or to change a colostomy bag.   Less need for gender based cleaning staff.   Less impact when one toilet is being cleaned or serviced.

Additional Justification:  People have use unisex toilets on airlines for decades.   

Cost Impact: None 

 

 

 

 

!!  TABLE BELOW IS FROM PREVIOUS CODE DEV CYCLE !!
 AND MUST BE UPDATED

 

MINIMUM WC COMPARISON CHART

   Cell background colors indicates 
   RED    Minimums appear inadequate
   YELLOW  - Questionable minimums 
 BLUE  Minimums appear excessive
 GREEN Proposed change  


FEDERAL LAW 29 CFR 1910.141(c)(1)(i): Toilet Facilities
 

For an occupancy between  1-15 16-35

36-55

56-80 81-110 111-150 151-300
Total WC Minimums  1 2 3 4

5

6 12

UNIFORM PLUMBING CODE  2006 RESTAURANT  PUBS & LOUNGES 

For an occupancy between  1-14 15-100

101-300

301-500 501-700 701-900
Total WC Minimums 1 8 10   12 

 

BASELINE  -  RESTAURANT  PUBS & LOUNGES

Occupancy  1-15 16-50 51-100

101-150

151-300 301-450 451-600 601-750- 751-900 901-
Unisex 1 2 . . . . . . . .
Male  . . 2 2 2 3 4 5 6 7
Female  . . 2 3 4 5 6 7 8 9

UNIFORM PLUMBING CODE  2009   MNTF RESTAURANT  PUBS & LOUNGES 

Occupancy  1-14 15-100

101-300

301-600 601-900 901-
Unisex 1 . . . . .
Male . 5 6
Female . 5
IPC 2009    A-2 RESTAURANT
Occupancy  1-15 16-150

151-300

301-450 451-600 601-750 751-900 901-
Unisex 1 . . . . . . .
Male . 1 2 3 4 5 6 7
Female . 1 2 3 4 5 6 7
PROPOSED 2009    A-2 RESTAURANT  
ccupancy  1-15 16-150

151-300

301-450 451-600 601-750 751-900 901-
Unisex 1 . . . . . . .
Male . 1 2 3 4 5 6 7
Female . 1 2 3 4 5 6 7
I

 

IPC 2009    A-2 PUBS & LOUNGES
Occupancy   1-15 16-80

81-160

161-240 241-320 -400 -480 -560 -640
Unisex 1 . . . . . . . .   .
Male . 1 2 3 4 5 6 7 8
Female . 1 2 3 4 5 6 7 8

Note: Would be useful if only 1 of 2 Unisex was ADA but this requires Federal Clarification for indoor.  

PC 2009    A-2 PUBS & LOUNGES
Occupancy   1-15 16-80

81-160

161-240 241-320 -400 -480 -560 -640
Unisex 1 . . . . . . . .   .
Male . 1 2 3 4 5 6 7 8
Female . 1 2 3 4 5 6 7 8

Note: Would be useful if only 1 of 2 Unisex was ADA but this requires Federal Clarification for indoor.  

 

 

 

 

IPC 2006 USE GROUP M is significantly significantly at variance with the UPC and appears to be under provisioned at higher occupancies.

UNIFORM PLUMBING CODE  2006 RETAIL & WHOLESALE  (EQUIV IPC USE GROUP M)   Note14 does not apply

For an occupancy between  N 1-50

51-200

201-400 401-600 601-800
Total WC Minimums 1 1M:1F 2M:2F 4M:4F   M=2w+2u 6M:6F M=3w+3u 14 (6M:8F)

IPC 2003 USE GROUP M 

For an occupancy between  1-50 51- 1000
Total WC Minimum  1 2  
  

"AT LEAST" CHANGE RECOMMENDATION FOR IPC 2003 USE GROUP M 

For an occupancy between  1-50 51-100
Total WC Minimum  1 2M:2F

 

IPC 2006 USE GROUP B  is significantly significantly at variance with the UPC and appears to be under provisioned at higher occupancies.

UNIFORM PLUMBING CODE  2009   OFFICE 

Occupancy  1-100 101-200 201-400 401-800 800-1100  
Male 2 2 4 6 8  
Female 3 4 8 11 12  
IPC 2009    Business
Occupancy  1-50

51-100

101-200 201-300 301-400 401-500 501-600
 Male 1 2 3 4 5 6 7
Female 1 2 3 4 5 6 7
BASELINE     
Occupancy   1-50 51-100 101-200 201-300          
 Male                  
Femail                   

 

Note:  Going from 2 (1 locked for each gender) to 4 (2 WC for each gender) increases the capacity more then 2 fold. 
Note: The IPC allows urinals to be substituted for  50% the WC's
 

ADDITIONAL SUPPORT  

 

 

Billy Bob's in Texas - Largest Pub at 6000plud   fire-code occupancy

Many small business owners are unaware that many people hesitate to visit restaurants where they may have to queue to use the toilet.  The proposed changes are likely to benefit the very business's who are opposed.  For example, 

McDonalds - While not verified, most if not all McDonalds restaurants appear to have more plumbing fixtures then required by the IPC.   Most likely they do this to improve the bottom line.

Most if not all Panera's Bread restaurants have max occupancies that fall within the IPC requirement for 2 toilets for occupancies up to 150.  Per a phone email discussion, they confirmed that all of their restaurants use non-customer locked multi WC restrooms.  There implementation fall within the  RECOMMENDED CHANGE TO  2009 IPC A-2

Recently a Whole Foods Store (has both A-2 & M) removed 2 SOR and replaced them with non-customer locked multi WC restrooms.   The retrofit was more expensive then if done at the design stage but customer complaints justified the upgrade.

  

TOILET FOOTPRINT COMPARE 

Single Occupant  ADA - 1 WC with no stall, 1 lav, occupant locked

  • (left to right) 18 “ from wall to center of wc + 42” to edge of sink (required) + 11” (approx) from edge of sink to center of sink + 15” from center of sink to wall = 86”
  • The 60” turning radius determines the perpendicular dimension
  • A wall-hung wc & wall-hung lavy would not take away from the 60” turning radius
  • 86 X 60 = 5,160 sq in
  • 5,160 / 144 = 35 .8
  • 74 sq ft – 36 sq ft = 38 sq ft increase per restroom

Multi-Occupant: 1 ADA and 1 standard  WC with  1 lav, 

  • 60” inside dimension for accessible toilet stall (side to side) + 1” for privacy partition + 30” side to side for an additional water closet. (a urinal could fit in the same 30”) = 91”
  • 56” (minimum accessible stall depth) - from back wall toward entry door - + 1” + 60” turning radius = 117”
  • 117 X 91 = 10, 647 sq in
  • 10,647 sq in / 144 sq in per 1 sq ft = 73.9 sq ft
  • Increase over SO = 76 sq ft  

Multi-Occupant: 1ADA WC and 1 urinal  with 1 lav, 



I took a closer look at the minimum restroom dimensions and realized we weren’t considering all possible restroom configurations. It looks like you could fit a 2 stall, 1 lav, multi-occupant, accessible restroom, in a 74 sq ft. rectangle measuring 7’ 7” X 9’ 9” . The key is side by side stalls facing the entry door with the lavatory on the right or left as you enter. I know you trust me but you should check my math (and logic) anyway. If you hadn’t checked me on this earlier our figures would have been way off.

 Here’s how I got there: One important thing to remember is the entry door for the multi-user restroom must swing outward, which is permitted by code. I think most restroom doors actually push inward but this minimum footprint restroom would need an out-swinging door.

It makes a lot of sense if you sketch out a floor plan like this: Line the entry door up with the HC stall. HC stall door swings outward against its adjacent wall. Put the lavy on the side where the standard stall is & keep it 15” to center from the far corner. This allows the other stall door to open against its adjacent wall without hitting the lavatory. Let me know what you think because I’ve been off my game the past few days.

 

 

CAPACITY DEFICIENCY OF A SINGLE WATER CLOSET (WC) TOILET 

The time interval required for people to satisfy their sanitation needs varies considerable.  For example, all  APT's  have timers that auto-open the doors after a set interval.  Every municipality in the U.S. has found that they must allow at least 15 minutes per person with many set at 20.   One city is now allowing a one-time over-ride that allows that time to be extended.   While many people are in & out in less than a minute, for those waiting in line,  it is a significant problem when someone occasionally needs the long interval.

This occasional extended time use of a WC can happen in any toilet facility.   Since extended use happens infrequently, a restroom with multiple WC's is less likely to have the problem.   A single WC restroom, however, will have the same problem as an APT.

 ARA's position is that where the minimum requirement is 1 men's and 1 women's,  a more effective use of resources would be 1 ADA unisex and 1 non-ADA unisex.  Besides improved availability the configuration would: cost less, provides inherent gender parity and allow one unit to be a backup when the other is serviced or cleaned.   They also act as family restroom for opposite gender care givers.  Cost can be further reduced since this configuration allows the occupancy threshold point to be increased before a 2nd WC facility is needed.    Additionally, it appears that USE GROUP B with an occupancy of 51 would have 2 unisex toilets.  (based on '03)

 

Federal Law 29 CFR 1910.141(c)(1)(i): Toilet Facilities 

(c) Toilet facilities--(1) General. (i) Except as otherwise indicated in this paragraph (c)(1)(i), toilet facilities, in toilet rooms separate for each sex, shall be provided in all places of employment in accordance with table J-1 of this section. The number of facilities to be provided for each sex shall be based on the number of employees of that sex for whom the facilities are furnished. Where toilet rooms will be occupied by no more than one person at a time, can be locked from the inside, and contain at least one water closet, separate toilet rooms for each sex need not be provided. Where such single-occupancy rooms have more than one toilet facility, only one such facility in each toilet room shall be counted for the purpose of table 
J-1.

Table J-1
------------------------------------------------------------------------
Minimum number of Number of employees water closets \1\
------------------------------------------------------------------------
1 to 15.................................................... 1
16 to 35.................................................. 2
36 to 55.................................................. 3
56 to 80.................................................. 4
81 to 110................................................ 5.
111 to 150.............................................. 6
Over 150............................................. (\2\)
------------------------------------------------------------------------

Source: U.S. Department of Labor Occupational Safety and Health Administration
29
CFR 1910.141(c)(1)(i): Toilet Facilities

 

From the 2006 UNIFORM PLUMBING CODE Table 4.1

 

 

The numbers in the comparison chart are greater then the minimums in table 4.1 based on the additional requirements of Note 14

NOTE 14: The total number of water closets for females shall be at least equal to the total number of water closets and urinals required for males.

ARA Note: Besides a WC each male sanitary facility must have at least 1 urinal.  Note 14 is therefore significant.  Since the male SF must have at least 1 WC and 1 Urinal,  the minimum requirement for women is 2 WC.  Because there is no provision for less then 2 fixtures in each room, the rooms should not be locked or it will reduce the intended availability of fixtures  

NOTE 16:  A unisex facility (one water closet and one lavatory) may be used when the customer occupant load for the dining area, including outdoor seating area, is 10 or less and the total number of employees for the space is 4 or less. 

__________________________________________________________________-

2006
UPC

 

 

 

 

FROM THE 2003 NATIONAL STANDARD PLUMBING CODE



Item 13 requires a summation for total WC count  

Notes for Table 7.21.1:

4. Whenever both sexes are present in approximately equal numbers, multiply the total census by 60% to determine the number of persons for each sex to be provided for. This regulation only applies when specific information, which would otherwise affect the fixture count, is not provided.
5. Not more than 50% of the required number of water closets may be urinals.
6. In buildings with multiple floors, accessibility to the fixtures shall not exceed one vertical story.
7. Fixtures for public use as required by this section may be met by providing a centrally located facility accessible to several stores. The maximum distance from entry to any store to this facility shall not exceed 500 feet.
8. In stores with floor areas of 150 sq. ft. or less, the requirements to provide facilities for use by employees may be met by providing central facilities located accessible to several stores. The maximum distance from entry to any store from this facility shall not exceed 300 feet.
9. Fixtures accessible only to private offices shall not be counted to determine compliance with this section.
12. Requirements for employees and customers may be met with a single set of restrooms. The required number of fixtures shall be the greater of the required number of employees, or the required number of customers.
13. Food service establishments with an occupant load of 101 or more customers shall be provided with separate facilities for employees and customers. Customer and employee facilities may be combined for customer loads of 100 or less. 

 

2007 SUPPLEMENT TO THE IPC IPC-8 

Section 403.1.1 Change to read as shown: (P28-06/07; E185-06/07)

403.1.1 Family or assisted-use toilet and bath fixtures. Fixtures located within family or assisted-use toilet and bathing rooms required by Section 1109.2.1 of the International Building Code are permitted to be included in the number of required fixtures for either the male or female occupants in assembly and mercantile occupancies.

Section 403.3 “Number of occupants of each sex” Delete without substitution: (P32-06/07)
(Renumber subsequent sections)

Section 403.5.1 Add new section to read as shown: (P34-06/07)
403.5.1 Directional signage. Directional signage indicating the route to the public facilities shall be posted in accordance with Section 3107 of the International Building Code. Such signage shall be located in a corridor or aisle, at the entrance to the facilities for customers and visitors.

 

                                                                                                                                                                         

American Restroom Association                                      
PO Box 65111                                                                        
Baltimore, MD 21209
202-747-6031 - Policy and Media queries 410-358-9007(FAX)

WARNING AND DISCLAIMER: The American Restroom Association (ARA) is formally incorporated in the State of Maryland and is a subsidiary of the International Paruresis Association  ARA is not qualified to provide legal advice. This web site contains non-vetted information that is un-official and for education only. There are no formal or financial agreements with any persons or entities cited. Some material is from copyrighted sources. This material is for education only and it must be source referenced.

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