36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. Water closets not in compartments require clearance that is at least 60 inches wide and 56 inches deep. Many comments urged the Board to increase this depth so that at least 48 inches is provided in front of the water closet. Others recommended an overall depth of 78 inches.

Response. The Board has not revised the minimum dimensions for the clear floor space at water closets. Other criteria for toilet rooms, including turning space, maneuvering space at doors, and clearances at other fixtures, typically results in additional clearance at water closets not in compartments. The 48 inch specification measured from the leading edge of the water closet is derived from the ANSI A117.1-1992 standard. That specification was removed from the 1998 edition of the ANSI standard because it was extremely difficult to enforce due to the varying installation styles and sizes of water closets. However, the Board has revised the specified depth in residential dwelling units where lavatories are permitted to overlap the space aside water closets.

Other fixtures, such as lavatories, generally are not permitted to overlap the clearance required at water closets. However, in residential dwelling units, an accessible lavatory adjacent to water closets can overlap this space (18 inches minimum from the water closet centerline) if additional space is provided in front of the water closet. Specifically, the depth of the clearance must be at least 66 inches instead of 56 inches (604.3.2, Exception). The proposed rule required this additional space in front of the fixture where only a forward approach to the water closet is provided (1102.11.5.2). It did not require additional space where a side approach to the water closet is provided. Locating lavatories outside the specified water closet clearance allows more options in the approach and transfer to water closets. The overlap of an adjacent lavatory effectively precludes side transfers to the water closet. The Board believes that additional space where lavatories overlap water closet clearances can be beneficial regardless of the approach direction. In the final rule, the 66 inch minimum depth applies whether a forward or a parallel approach to the water closet is provided. The proposed rule also allowed a minimum width for the clearance of 48 inches instead of 60 inches where a lavatory overlaps the space, regardless of the approach (1102.11.5.2). In effect, however, space at least 60 inches wide is needed in meeting other requirements, such as the clear floor space required at the adjacent lavatory and wheelchair turning space. Consequently, the Board has removed the 48 inch specification in the final rule.