Problem Areas and Solutions

Area of Concern

Shopping Malls, Stadiums, Interstate Highways, our National Parks and the Work Place all have toilets.  Unfortunately there are still locations and situations that can significantly complicate the enjoyment of life, at least for some.  Here are some specific areas of concern:

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Shopping Malls, Stadiums, Interstate Highways, our National Parks and the Work Place all have toilets.  Unfortunately there are still locations and situations that can significantly complicate the enjoyment of life, at least for some.  Here are some specific areas of concern:

The Town Comfort Station

At one time many municipalities had comfort stations in their business district.  Over time, units were closed to save cleaning costs and move crime elsewhere.  These closings came at an unanticipated price. Besides an increase in civility law violations, business was hurt when visitors realized they were out of  luck when they needed ‘to go’. (1)   Fortunately, the trend appears near apogee.  Some cities have reopened their still existing facilities, while others create small flowered parks around a public restroom.

In the photo below, public restrooms are placed at the entrance of a Municipal Parking Garage.

The garage does not close and is staffed with an attendant. Cameras record activity and the kiosk operator has an unrestricted view of restroom entrances.  This implementation stops vandalism, and provides protection to users.  The garage is commercially operated and the contract includes maintaining and cleaning the toilet facilities.

Expanded View

CUMBERLAND, MD …According to statistics kept by the Allegany County Visitors Center… more than 5,600 asked where they could find a restroom.  Many local businesses place signs at entrances telling people there are no restrooms available to the general public.
Cumberland Times-News  ‘Many visitors seek downtown restrooms’  3/11/07DENVER,CO … another problem she has with the parade is the lack of public restrooms. She says people constantly ask to use her restroom, which isavailable to paying customers only. We have people come in that are just furious that they can’t use the restroom.”…
Steve Shultz/ on 12/18/2006

ROCKLAND NY The restroom law• Events covered: Recreational activities, fairs, carnivals, religious gatherings or similar outdoor events.• At least one toilet required for every 100 people in attendance.• Property smaller than 20,000 square feet does not have to have toilet facilities, but any existing toilet facilities must be open and working properly.
Bathrooms required at Rockland events Journal News White Plains, NY Oct 27, 2005

TOPEKA,KS … in addition to the concrete, skaters complain about the lack of a restroom nearby. Park regulars say it is not uncommon for kids to urinate in public and it causes an unpleasant smell.
WIBW-TV ‘Skaters Complain New Skate Park Isn’t Adequate’  6/20/08

HOUSTON TX  … director of parks and recreation, says that in response to resident demand, the parking lots will be expanded at both parks, and permanent restrooms will be installed …
Sugar Land plans for additional amenities at Oyster Creek  3/30/04

SCOTTSDALE AZ – Shoppers now have convenient, affordable, sturdy structures to park their cars while shopping in downtown Scottsdale.  It is free andavailable 24 hours a day, seven days a week. It even has restrooms and, of course, an elevator.
Downtown Scottsdale adds parking   Deborah Bingham The Arizona Republic Jun. 6, 2005

SEATTLE WA  The state Department of Transportation is well aware of the problem of travelers relieving themselves in inappropriate places along the highway,…  The DOT has a goal of providing a safe and sanitary place to rest every 60 miles on rural highways
The Roadside Not Truckers’ Toilet  The Seattle Times 9/29/06

Another innovative solution – Some municipalities reimburse local business establishments that announce their restrooms are open to the public with no requirement to purchase.(2)

(1) Visitors frustrated by lack of facilities Detroit News Mar 26 ’02
(2) At last, downtown Geneva visitors will have place to go  Chicago Daily Herald 8/703

Restrooms Exist but Where?

Street Sign above Comfort station

Many locations have excellent public toilet facilities but few know where they are located.  Even when not a stand-alone public restroom, facilities are often available at such entities as Community Centers, Parks and Athletic Fields.   This is one of the most frustrating and least expensive problems to fix.

Source: If women ran the world

To get the best return on their public restroom investment:

  • Municipalities should have signs at key locations and note them on Tourist Maps
  • Larger cities should provide toilet maps

Multi-use Trails

A low-cost effective method of leveraging an existing asset are signs that guide trail users, especially the first time visitor, to existing nearby toilet facilities.
Commuter Parking Lots

Used as start points for mass transit, or ‘car pools’, commuter parking lots often involve waiting.  This wait-time adds to the time it took to get there.  Worse, after the car pool is formed, the riders face a potentially long trip ahead in slow rush-hour traffic.  Adjacent wooded areas provide evidence of the problem.  Often, uncaring public works officials will remove shrubs rather than provide a chemical toilet.

When a portable-toilet is provided, placement should consider esthetics, security, and maintenance.  Commuter Parking Lots typically are in open areas and have overnight and weekend periods of inactivity.  A sufficiently wide base, partial fencing or other measures should be considered to prevent tipping by wind or bored teenagers.

Transit Systems

The Building Code adopted by most municipalities requires at least 1 male and 1 female restroom at all transportation passenger terminals.   Unfortunately, this code is not always followed(1).

An interesting example is York Pennsylvania’s new “spoke and hub” Bus Transfer Center.  While it features a climate controlled waiting area, it does not allow riders to use its restrooms.   Rabbit Transit is not the exception.  For many years transit customers were not allowed to use the restrooms of the large and complex Washington D.C. Metro Transit System.  Fortunately, WMATA is working to resolve this problem.

No modern Commuter Transit System would intentionally design a station to preclude use by someone in a wheel chair.  The same philosophy must be applied to the “restroom challenged”.   Transit Stations without public restroom access have toilets for their staff.  Staff will occasionally honor a customer request; unfortunately, there’s no guarantee.  Changing System Policy to require honoring all customers’ toilet requests is a no-cost interim solution.

Where permanent facilities are not available, portable toilets should be placed in discrete, safe areas adjacent to stations. Stations with large sprawling parking lots should have a portable toilet in the area located the greatest distance from the station.

Japanese Subway Sign

(1) Restroom status of Subway Systems in North America

Athletic Fields and Small Parks

Ball field with no toilets, no shrubs, no trees and no relief

Many people, particularly women, are loath to play mixed gender team sports.  Male physiology makes going in the shrubs less onerous and men are less embarrassed by jeers of less-thoughtful team mates.  Those not willing to squat behind a shrub have two choices.  Avoid the activity or avoid fluids.

At the edge of a children’s play area unit is intended as much for mom as her her kids
Both choices have negative health implications.(1)

Besides serving those playing field sports, a field toilet is a boon for those walking, jogging, and the occasional driver in need of a pit stop.  Not everyone shares this view (see Occupant Locked Restrooms below).

(1) National Institutes of Health (NIH) Publication No. 95-2754, July 1995

The 9 to 5 Problem

Many cities have facilities that are available during the workday.  After hours, people in need are out of luck.  In many locations the typical “after hours fallback”  is a fast food outlet.  Unfortunately these establishment are often located at the town’s outskirts.

Municipalities, especially those with enforced “civility laws”, must provide alternatives. Cities sometimes close their “comfort station” at night to move nefarious activity elsewhere.  Signs on the locked restroom doors should provide alternatives.  Typically, municipal public safety operations are staffed 24 x 7.   A local police station can accommodate the few late night persons in need with minimal impact (1).  If there is excessive traffic then the Municipality has a restroom requirement that must be accommodated

As noted above, some cities have restrooms located in municipal lots within view of the parking attendant.  This configuration allows use without fear of crime.  Even bicyclists can seek relief without fear of bike theft.

(1) An intoxicated person may choose public incivility rather than visit the police station

Building Code Toilet Facility Requirements

The National Building Code adopted by most States provides well though-out “minimum number of toilet facility” recommendations.   As adopted by most States, the code, for example, requires a restaurant to have at least one men’s and one women’s toilet for up to 75 people.  On the other hand a for a night-club the maximum is ,reasonable, reduced to 40 people.   There are implementation of the code, however. that can results in people queuing to use the restrooms

(1) Outside seating distorts this formula.  For the most part these people are not occupying the building but they can be expected to use the restroom as often as those within.

(2) The formulas are based on a standard restroom configuration that allow more then a single person at a time in the room.  When the door to the restroom can be locked this reduces how many people can use the restroom at a given time (see Occupant Locked Restrooms below).

(3) There typically is no consequence when a restroom is closed for cleaning or for repair.

(4) When an occupant of a building is not allowed to use a restroom, redress is difficult.

Occupant Locked Restrooms

Large well planned restaurant chains, such as McDonalds, have restrooms with non-locking doors.  Toilet stalls provide the necessary privacy.  Even if you have to wait, it’s typically not long.  Many establishments, however, have small rooms with a single toilet.  The doors ‘slide lock’ from the inside. Occasionally this can be a problem.  It may be an employee having a smoke break or the town drunk passed-out.  Especially after a long drive the ‘uncertainty’ can be excruciating.  For many, thinking you’re seconds from relief, then being denied, results in an urgent situation.

A non-locking restroom configuration assures that customers can at least wash their hands before eating. More importantly this configuration prevents misuse.   Not just from employees taking an unauthorized break but also from criminal misuse (drug sale, prostitution).   Prohibiting Smoking in restroom would probably improve their availability.

Unisex Restrooms

Some small business establishments have only space for one genderless ‘water closet’.(1)  Obviously, it must be locked.  At locations where there are two lockable restrooms, keeping both rooms genderless mitigates access problems. Typically, extended ‘lock-out’ will not occur simultaneously.  This solution, so obvious to some, is upsetting to others.  Some feel one sex is messier than the other.  Others misunderstand, assuming an ‘Ally McBeal’ type open room shared by both sexes.  When a Unisex restroom also includes a urinal women report less problems with messy seats, though other say the urinal makes them feel they are in the wrong bathroom.

Unisex Restrooms also are an inherently balanced solution to the ‘potty parity’ and some institution such as  Fullerton College have made successful conversions.

(1) IPC Code allows one unisex bathroom for buildings with a maximum occupancy of no more than 15 people

Office Buildings that require a key for restroom access

To assure building restrooms are used only by tenants and their guests, many Companies have keyed bathroom entry.   This configuration allows multiple people to use the facilities and affords additional security.  Unfortunately, this hindered access can be a problem for the restroom challenged.  After a long trip, for example, a person may desperately need to use the restroom as soon as they enter the building.  If they can’t quickly find the organization they are visiting their health is compromised.  Buildings should have at least one non-locked restroom near the entrance available for all occupants of the building.  Typically buildings in areas where there could be a problem with misuse already have access control procedures such as a guard.

We Regret the Inconvenience

Restrooms are sometimes closed in the middle of the business day.  Typically the signs offer no option even when alternatives exist.  At a food court, the closing also prevents customers from washing hands before eating.   While at variance with existing public health requirements, enforcement is lax.

Those responsible for cleaning the restroom should provide directions to the next closest restroom.   If none are nearby, the restroom should be cleaned by the appropriate gender so that only a ‘Caution – Wet Floor’ sign is required.

See also East Carolina University’s thoughtful ‘Temporary Restroom Closing’ Policy.

The For Customers Only Spiral

In towns without public facilities, restaurants often get non-customer traffic using their bathrooms. Soon one establishment hangs the dreaded “Customers Only” sign. This worsens the problem for the remaining restaurants.  Few weeks pass before every business in town, including service stations, sports the warning.

Building codes require that all occupants be allowed to use the restroom, but enforcement is difficult.  Some Municipalities have passed additional  legislation specifically mandating that non-customers be accommodated.  Here is an interesting concept being considered:  Geneva, Ill will reimburse a business that is willing to publicize public restroom availability.

Vagrants, Vandalism, and Crime

The often hidden reason for the limited availability of public restrooms.

Being a customer doesn’t always help.  Get off the Interstate for gas at night in the center of a big city and you may find the attendant, behind a bulletproof screen, and the facilities locked, No Exceptions!

Delaware’s Rehoboth Beach officials recently announced tougher enforcement of their ‘civility laws’.  What’s missing from the story: Rehoboth began closing its three public restrooms in late evening to keep out the ‘riffraff’.  Their boardwalk is often quite active when their facilities are locked.  Police have no guidance for those needing help.

Transit officials will often admit they should have more restrooms but they don’t want to deal with ‘vagrant occupation’ concerns.  It’s perhaps one of the best examples of unintended consequence of our ‘well-meaning’ lack of support for vagrancies laws.  Punishing the innocent to solve social and security problems is wrong.   Worse, closing restrooms to solve misuse exacerbates the problem.  Just as allowing graffiti to remain in place, bolted restrooms signal menace as does the smell of urine in the stairwell.

Listed are design steps that can reduce misuse of public restrooms:

  • Curve or “L” door-less entrances (provide privacy but reduce sense of habitat)
  • Security mirrors aligned to protect privacy while improving site lines.
  • Stall doors that:
    • swing inward (impedes surprise exit)
    • are no lower or higher then required for privacy (also improves efficiency – unoccupied stall are clearly visible)
    • have indication of occupancy (red/green)
  • Spring loaded stall doors that are open (inward) when not in use
  • Restrooms heated only enough to prevent freezing
  • Bright lighting and windows (at least with sight-lines to the wash area)
  • Signs stating local ordinances and rules of use
  • Willingness of Police and Courts to enforce rules
  • Nearby Pay Phone which allow suspicious activity to be reported
  • Implementing entrance audio and video surveillance with signed warning

The doors of these three toilets are chain locked!

These toilets are intended to service a large multi-use athletic field and they are also adjacent to a popular paved trail that loops around the edge of the park.   As the worn dirt trail leading to the units attests, they are heavily used.  When asked, a Municipal Park and Recreational employee said the lock-out was caused by ‘over-use’   He explained, with no sense of irony,the units were intended for the ball fields but pedestrians from the paved trail were also using them.


In the past a town’s municipal building that housed 24X7 operations typically provided an available off-hours restroom.   Especially since ‘Sept 11’ many Federal, State and even Local government buildings now apply stringent access control.  Even buildings housing police operations are now locked.    This ‘fortress’ approach, much like graffiti, signals danger.   Tourism is hurt and people living nearby have one more concern if there are no other restrooms, when they walk in these towns.

Closed for the Winter

Serious cyclists, joggers and walkers are active year round.  Unfortunately many unheated public facilities must be closed before the first freeze.   Ironically, feeling a chill can lead to a more frequent need.  While there are fewer people outside in cold weather, those that are outside need facilities with greater frequency than during the warmer months.

Caring municipal officials place portable toilets at Parks and Athletic Fields year round.  They place ‘porta-jons’ by unheated public facilities closed before the first freeze.

Many municipalities rent portable toilets.  They are reluctant to pay monthly rental costs during the less used winter months.  Typically these rental costs are mostly the cost to service the unit.  An alternative is for cities to own portable toilets and procure only the cleaning service.  Service intervals can be lengthened in winter months.  If purchased and maintained thoughtfully, the life cycle cost of a year round chemical toilet can be less than partial year rental.

Chemical Toilets Placement and Service

Porta-Potties are a low cost, quickly implemented toilet availability solution.  Unfortunately, those in need use them with hesitance.  They are often improperly serviced and become foul smelling and unsanitary.  When installed on an uneven base they rock and can be easily tipped.

Properly sized units with the proper service interval remain sanitary and odor free.  Units should be purchased with water-less hand cleaner dispensers and they should be based on a solid flat surface.   Those government entities who issue permits for Special Event should mandate strict portable toilet facility count requirements.

Wood slat fence surrounds two toilets

If the units are to be installed on a permanent basis, a commuter parking lot for example, a three sided wood slat fence provides a cosmetic improvement and a concrete base provides stability that improves user acceptance.  The photo at the left shows how a wood slat fence improves the view from a Park Picnic area.

Self Cleaning Public Toilets/Pay Toilets

Automatic Public Toilets (APT) are low maintenance self-cleaning units.  They cut labor cost but still require some maintenance, typically via a service contract.  Some municipalities budget the cost, while others sell advertisement space in and on the unit to defray or offset the need to charge.  In a worst case situation the APTs are used as a revenue source.  The Public Restroom Initiative appreciates efforts that increase availability but does not endorse charging for basic human functions.(1)

(1) Intl Plumbing Code Sect 403.6.2 Pay facilities: Required facilities shall be free of charge …

National Toilet Code Limitations

In the United States, the International Code Council (ICC) generates the National Model Plumbing Code (IPC) adopted by almost all States.  This code provides well thought-out and well-vetted requirements for the availability of public toilets in structures.  There are also OSHA(1) Codes of Federal Regulation (CFR’s) that mandate employee restrooms.  Outside the work place, with a few exceptions(2) there is remarkably no National Public Health mandate for toilet facilities.

(1) Department of Labor’s Occupational Safety & Health Administration
(2) Land controlled by the National Park Service, locations where food will be handled, and FEMA Special Events Toilet Guidelines

Enforcement concerns with existing Code

While State Building Codes typically mandates toilet facilities for all occupants of a building (not just customers), enforcement is weak.  If not a food service, refusal to allow someone to use a restroom in a business establishment is a ‘ building code’ violation.  Municipal commercial code enforcement persons prefer citing violations they can inspect.  They typically lack the interest or forte to follow up on a ‘not allowed to use’ complaint.

One provision of the Americans with Disabilities Act (ADA) regulations also need to be strengthened.  While ADA rules provide well defined accessibility standards when a structure is built or renovated, these guidelines don’t require that there be a restroom.  Some outdoor toilet facilities are simply closed when challenged to meet ADA accessibility requirements. Requiring accessibility for the ‘physically challenged’ is of no value in those cases where the guidelines are satisfied by removal.


An appropriate Agency of the United States Department of Health and Human Services (HHS) should sponsor a broadly applicable toilet facility CFR.  As an immediate stop-gap, even a non-binding ‘Position Statement’ by an Agency of the HHS would be a significant improvement over the existing situation.   Likewise, the U.S. Access Board should strengthen its ADA regulations to preclude removal of an existing toilet facility as a method of resolving an accessibility complaint.

Sample Media Coverage of the Issue

At last, downtown Geneva visitors will have place to go  Chicago Daily Herald 8/703
…public restrooms, housing top list of downtown concerns  Citizen Times – Ashville NC Feb. 18, 2003″
Visitors frustrated by lack of facilities  Detroit News Mar 26 ’02
Search for a public bathroom became an odyssey humiliation The Onion V38#31
Public restrooms in sad shape  Pittsburgh
If You Have to Go, Perhaps Soon You Can Go on Metro Washington Post  1/5/03

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