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Restrooms for Restaurants in California

This article has been updated for 2019 California Retail Food Code here »

Do you have an older restaurant, coffee shop, cafe, or snack bar located in California and are wondering what to do about the restroom(s)? There are several things you should be aware of.

• There were no requirements for restrooms for your patrons if the building was constructed before January 1, 2004 and it is less than 20,000 SF. If you do have space for food consumption but no restrooms you would need to post a sign in a public area stating Public Restrooms Not Available per the California Uniform Retail Food Facilities Law – Section 114120.
• If your restaurant did have restrooms constructed after January 1, 1985 but the path of travel is thru the food preparation area or a storage area they shall not be used by customers per Section 114105.
• If your restaurant is greater than 20,000 SF and it was constructed between July 1, 1984 to January 1, 2004 you are required to have 1 minimum restroom for your customers for men and another for women.
• Any new building constructed after January 1, 2004 that has a restaurant with on-site food consumption or is greater than 20,000 SF is required to have restrooms for customers.
• Whether required or not, if restrooms are provided for the public they should meet Accessibility standards.

If you have restrooms for your patrons, whether or not they were required, that were constructed after January 26, 1993 or were altered after January 26, 1992 they should be made accessible. If they do not comply with these 1991 standards then come March 15, 2012 they are required to comply with the 2010 ADA Standards. However since you are in California, when the restaurants are altered they will need to comply with the current California requirements as well.

If you have restrooms that were pre-ADA then you will need to remove barriers that are Readily Achievable. You can not do nothing – being an older facility is not an excuse and it is expected that you will do as much as possible, readily achievable, in order to make them accessible.

And finally, if you did a remodel on any portion of your facilities containing a primary function you would be required to spend an additional 20% to make path of travel items accessible, which includes restrooms. There is a cap on the 20% rule which is dependent upon the overall cost of your alteration and this amount changes upwards annually.

Be aware that your local City or County may have additional requirements that are more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer. It is meant as a summary – current original regulations should always be reviewed when making any decisions.

© Janis Kent, Architect 2012