STATE BUILDING CODE INTERPRETATION NO. 01-01

CODE:

State Regulations for Barrier-Free Facilities

SECTION:

1106.11.5 Water closets: 1106.11.5.1 Clear floor space, 1106.11.5.2 Height, and 1106.11.5.3 Grab bars

QUESTION:

1. Department of Social and Health Services(DSHS) regulations require toilet fixtures to be approximately 11 inches high for toddlers and younger preschoolers. State Regulations for Barrier-free Facilities specifies a height of 17-19 inches with no exceptions shown for children or daycare facilities. DSHS regulations (WAC 388-150-340), however, do not require grab bars and clear floor space for any water closets used by toddlers and preschoolers.

Can grab bars and clear floor space for water closets be omitted from daycare restrooms intended strictly for toddlers and younger preschoolers in Group E-3 Occupancies when they are licensed and approved through DSHS and meet the requirements of WAC 388-150-340?

2. Is it the intent of the Regulations for Barrier-Free Facilities to require grab bars and clear floor space for at least one water closet in all restrooms, including those in Group E-3 Daycare Occupancies?

3. Can the building department accept clear floor space and grab bar dimensions per some recognized standard (along with the lower water closet height) as an equivalent alternative to the state barrier-free requirements (ADAAG, for example, identifies clear space, height, and grab bar dimensions specifically for children)?

ANSWER:

1. No.

2. Yes. See also State Building Code Interpretation No. 92-86 and Section 1112.3.7.1.

3. Yes. See also State Building Code Interpretation No. 00-09, Question 1.

SUPERSEDES:

None

REQUESTED BY:

City of Bellevue