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The new proposed accessibility standards published by the US Access Board in July 2004 and amended in August 2005 are not yet final or enforceable, but are closer to becoming a reality. Following public input, the process continues and is one step closer to evolving into final, enforceable standards.

When the proposed new guidelines will be final and enforceable is yet to be determined. The Department of Justice has stated that the guidelines may be final in 2007. Others are reluctant to offer a specific date.

During the interim and to assist in the transition, it is important to become aware of the current and the proposed standards for accessibility. There may be some areas or items that currently exist in your facility that may be out of compliance with the current standards, but will be in compliance with the new proposed standards. Significant money can be saved by understanding the current and the proposed standards. In addition to renovations and remodeling, an opportunity  exists during the regular maintenance schedule to make changes that will improve accessibility and compliance with the law.

For example, reinstalling or replacing a sign provides an opportunity to comply with accessibility regulations. Installing or reinstalling a mirror or a toilet paper dispenser to the correct height and location will assist with making a toilet room more accessible.

This article focuses on one common area—toilet rooms. The article is not meant to discuss all of the requirements for a toilet room. Some of the more common areas of accessibility compliance for a toilet room are discussed along with a comparison of the current and new standards. The current and proposed new standards of the Americans with Disabilities Act Accessibility Guidelines (ADAAG) are utilized. As some states may have standards that provide a greater level of accessibility than the federal ADAAG standard, it is important to review your state’s standards in addition to the federal ADAAG standard.

Let’s review the more common requirements for toilet room accessibility using the current and the new proposed standards. The new proposed standards use Chapters to outline scoping requirements and accessibility elements. Chapter 2 out-lines scoping requirements for toilet facilities and bathing facilities. Chapter 6 outlines the technical requirements for plumbing elements. Specific chapter references, such as 603.3 (mirrors) are provided.

Water Closet Centerline
One of the more significant changes is in regards to the water closet centerline. Currently, the distance from the wall to the centerline of the water closet requires an absolute measurement of 18”. The new standards will pro-vide for a range from 16” to 18” in a standard compartment and from 17” to 19” in an alternate compartment.

Water Closet Clearance (604.3.1)
For a singe user toilet room, clearance around a water closet is required to be a minimum of 60” measured perpendicular from the side wall and 56” measured perpendicular from the rear wall. The current standard allows for 42” clear space (ADAAG 4.16.2) measured from the centerline of the water closet in the direction of the wide side (opposite the side grab bar wall).

Water Closet Seat Height (604.4)
The set height of a water closet above the finished floor is required to be between 17” and 19” for adults, measured to the top of the seat. The new proposed requirement is the same as the current standard, with the exception of children’s standards.

Grab Bars (604.5)
The length requirements of a minimum of 42” for the side grab bar are the same in the current and new standards. Using a 42” grab bar requires the installer to place the grab bar exactly 12” from the back wall in order to mount the grab bar at 54” from the rear wall. Using a 48” grab bar provides for greater flexibility.

Toilet Paper Dispensers (604.7)
The new standards require the toilet paper dispenser to be a minimum of 7” to a maximum of 9” in front of the water closet. The toilet paper dispenser is measured to the center of the dispenser.

The outlet of the dispenser shall be a minimum of 15” to a maximum of 48” above the finished floor and shall not be located behind grab bars. Dispensers can not be of a type that controls delivery or interferes with a continuous paper flow above the finished floor.

Urinal (605)
Urinals are required to be in a stall or wall hung type. Stall-type urinals generally provide greater accessibility to a broader range of persons with disabilities, including persons of short stature. The maximum height of the rim is 17” above the finished floor. The new standards will require the urinal to be a minimum depth of 13 1/2” from the outer face of the urinal rim to the back of the fixture. The current standards do not specify a distance from the back wall.

Ambulatory Compartment (604.8.2.1)
The current standard requires a 36” wide compartment. The new standard will require a 35” minimum to a 37” maximum in width.

Lavatories (606.3)
One of the more significant changes regarding lavatories concerns knee clearance. The current standard requires 29” of knee clearance. The new standard will require only a 27” clearance with a maximum lavatory height of 34”.

Faucets (606.4)
Hand-operated metered faucets are required to remain open for a minimum of 10 seconds.

Mirrors (603.3)
In the current and the new proposed standards, mirrors are required to be installed with the bottom edge of the reflecting surface to be no more than a maximum of 40” above the finished floor or ground. It is important to remember that the reflecting portion of the mirror, not the frame, be at a maximum height of 40”. The new standard states that mirrors that are not located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface to be a maximum of 35” above the finished floor or ground surface. The use of a single full-length mirror can accommodate a greater number of people, including children. The top edge of a single full-length mirror
should be a minimum of 74” above the
floor or ground.

Door Closers (307.4)
The vertical clearance under the new standard will be reduced to 78” instead of 80” above the finished floor.

Reach Ranges (308.2)
A change is also proposed in the area of reach ranges. The current reach range is 48” for a front approach and 54” for a side approach. The new standard will require a 48” reach range for both a front and side approach.

Door & Gate Surfaces (404.2.10)
The new standard will require that the bottom 10” of a door have a smooth surface from the push side of the door.

Signage Height (703.4.1)
The current standards require that signs be centered at 60” above the finished floor or ground surface. The new standards will require signs to be located at a minimum of 48” above the finished floor or ground surface, as measured from the baseline of the lowest tactile character and 60” maximum above the finished floor or ground surface, measured from the baseline of the highest tactile character.

Signage at toilet rooms is an example of state standards requiring an additional level of accessibility. California, for example, requires that a gender use symbol be placed on the toilet room door, in addition to the federal ADAAG requirement of signage on the latch side of the door.

Pictogram Field (703.6.1)
Under the new standards, the pictogram field shall have a field height of 6” minimum. Characters and Braille can not be located in the pictogram field.

Planning for Compliance
Removing barriers to access can be done most cost-effectively in coordination with an overall plan and a schedule of other construction and alteration activities. Keeping an eye on the evolution of the new standards will assist with planning efforts.

Barbara Thorpe is president of Disability Access Consultants, Inc. (DAC)—www.adaconsultants.com—a national accessibility consulting firm that has assisted with compliance with the ADA and related legislation by developing self-evaluations, transition/ barrier removal plans, facility inspections, training, consultation and accessibility software. She can be reached at 800-743-7067.

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