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Technical Memorandum TM 2013-17 Water Closet Clearance - Overlap

Associated

TAS 604.3.2 allows “associated” grab bars, dispensers, sanitary napkin disposal units, coat hooks, and shelves to overlap the required clearance around an accessible water closet. Based on the collegiate definition of “associate;” these elements are closely related or connected to the function and use of the water closet.

Dispensers associated with the use of a water closet and allowed to overlap the water closet clearance include seat cover, feminine hygiene product, disposal bag, and toilet paper dispensers. These dispensers must comply with all applicable provisions of TAS and cannot violate the protruding object requirements of TAS 204 and 307. Soap and towel dispensers and other dispensers unrelated to the use of a water closet may not overlap the water closet clearance.

Shelves and coat hooks provided for the placement of items and garments during the use of a water closet are allowed to overlap the water closet clearance and must comply with TAS 213.3.7. Only shelves and coat hooks are referenced in TAS 604.3.2, therefore, other types of storage such as supply closets and cabinets, clothes rods, and drawers may not overlap the water closet clearance.

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