Accessible Bathing Facilities as Defined by the ADA
Typical Bathing Facility with Roll-In Shower
Wheelchair accessible bathing facilities in Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). The sections of the 2010 ADA Standards that cover requirements for wheelchair accessible bathing facilities include 213.2, 213.3.6, 603, 607, 608 and 609. This article will discuss the ADA scoping requirements for wheelchair accessible bathing facility installations in State and local government facilities, public accommodations, and commercial facilities. The photo above is representative of a wheelchair accessible bathing facility that includes a toilet, sink, and roll-in shower. For the purposes of this discussion, the word “room” can be used in place of the word “facility”.
There is a significant amount of redundancy between wheelchair accessible toilet facilities and wheelchair accessible bathing facilities. Design issues such as clear spaces, reach ranges, and door maneuvering spaces are similar in each type of facility. Also, in both types of facilities there are single-user and multi-user versions. The main difference is that a bathing facility has at least one shower or tub. The graphic below is representative of the features of a wheelchair accessible bathing facility for a single user.
Bathing Facility Schematic
2010 ADA Standard 213.2, [Toilet Facilities and Bathing Facilities] Toilet Rooms and Bathing Rooms, states, “Where toilet rooms are provided, each toilet room shall comply with [Standard] 603. Where bathing rooms are provided, each bathing room shall comply with [Standard] 603.” In other words, in new construction, all bathing facilities must comply with the ADA, including employee only. There are exceptions for this Standard for technical infeasibility and clustered portable bathing facilities. There is no exception for clustered single-user bathing rooms.
2010 ADA Standard 213.3.6, [Plumbing Fixtures and Accessories] Bathing Facilities, states, “Where bathtubs or showers are provided, at least one bathtub complying with [Standard] 607 or at least one shower complying with [Standard] 608 shall be provided.” The exception for this Standard is where single user portable units are provided, at least 5% at each cluster must comply and be labelled by the International Symbol of Accessibility (ISA) unless all in a cluster are accessible.
Additions to a facility are required to comply with requirements in the Standards for new construction. Each bathing room of an addition must comply as would be required in new construction.
When existing bathing facilities/rooms are altered, the Standards apply according to the planned scope of work [2010 ADA Standard 202.3]. If one bathing room on a floor is altered, the Standards apply to that room only; if all bathing rooms on a floor are altered, the Standards apply to each bathing room that would be required to comply in new construction. The scope of work also determines which technical requirements apply. If some, but not all, elements in a bathing room are altered, only those elements altered must comply. If a room or space is completely altered (or built new as part of an alteration), the entire room or space must comply. Compliance in an alteration is not required where it is “technically infeasible.”
The different types of bathing devices include:
bathtub
roll-in shower
alternate roll-in shower
transfer shower
combination transfer/roll-in shower (required in some transient lodging rooms)
Each of these types of bathing devices will be discussed in depth in subsequent articles. While the requirements for each bathing device will be different, the requirements for the complimentary bathing facility elements to include a toilet and/or toilet compartment, sinks, mirrors, coat hooks, shelves, dispensers, and receptacles are the same. Other requirements in bathing facilities that will always apply are the requirements for clear spaces at elements, turning spaces within the bathing facility, and door maneuvering spaces. The graphic below is representative of some of these requirements in a bathing facility with a bathtub for a single user.
Clear Spaces for a Single User Bathing Facility with Bathtub Bathing Device
Unisex Bathing Rooms
Unisex Toilet Room Sign
Unisex Bathing Rooms are covered in 2010 ADA Standard 213.2. Unisex bathing rooms, where provided, must have privacy latches and contain a shower or shower and tub, a lavatory, and a water closet (2010 ADA Standard 213.2.1). Providing an accessible unisex bathing room in addition to accessible multi-user bathing rooms is helpful for those who use personal care assistants of the opposite sex. The International Building Code requires accessible unisex bathing rooms in recreational facilities with separate-sex bathing rooms that have more than one shower or bathtub fixture (§1108.2.1 in the 2000 IBC and §1109.2.1 in later editions).
Where multi-user bathing rooms are provided, accessible unisex bathing rooms cannot serve as a substitute for compliant multi-user rooms, except in alterations where making multi-user rooms comply is not technically feasible (2010 ADA Standard 213.2, Ex. 1). Otherwise, where multi-user and unisex bathing rooms are provided, both types must comply.
Bathing Facility Location
The 2010 ADA Standards do not generally require bathing facilities to be provided in a specific location. However, in multi-story facilities that are exempt from the requirement for vertical access between stories based on the story count or square footage per floor (2010 ADA Standard 206.2.3, Ex. 1 or 2), if a bathing room is provided on an inaccessible story, a bathing room also must be provided on an accessible story so that it is connected to an accessible entrance by an accessible route (2010 ADA Standard 213.1). Bathing rooms provided on other stories must fully comply as well.
SUMMARY
In new construction, all bathing facilities must comply with the ADA, including employee only. Each bathing facility of an addition must comply as would be required in new construction. When existing bathing facilities are altered, the Standards apply according to the planned scope of work. Where multi-user and unisex bathing facilities are provided, both types must comply. The 2010 ADA Standards do not generally require bathing facilities to be provided in a specific location.
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