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Bathing Showers vs Rinsing Showers

Janis Kent, FAIA, Architect, CASp © January, 2025

Bathing showers are what we typically think of in reference to the ADA Standards. But what is a bathing shower? It is not defined in the Standards nor the CBC under either bathing shower or rinsing shower or just plain shower. Basically, if you look up the word bathing it means to wash and has to do with personal hygiene. There are other meanings as well which have to do with rituals and ceremonial rites but that is not what is being discussed below.

If you review the ADA Standards in the scoping section under 213 Toilet Facilities and Bathing Facilities you will find the following.

213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.

213.3 Plumbing Fixtures and Accessories. Plumbing fixtures and accessories provided in a toilet room or bathing room required to comply with 213.2 shall comply with 213.3. 

Notice it discusses bathing rooms, not an individual or gang shower located outside. Now just because there are no scoping or technical requirements, does not mean access can or should be ignored.

The issue comes up – what about a rinsing shower? So how is a rinsing shower used? What can you use as equivalent, and does this need to comply with bathing shower requirements? And in my opinion, no, although access still would need to be provided. So where do you go for requirements? And first, what is a rinsing shower? It is not defined under ADA or CBC either. If you look under the Architectural Barriers Act (ABA) it does discuss rinsing showers. The below is taken from the 2014 Outdoor Developed Areas Summary

Outdoor Rinsing Showers [1011.2, 1011.3, and 1011.7] 

Outdoor rinsing showers allow people to rinse off sand, dirt, and debris. They are not intended for bathing. Outdoor rinsing showers generally don’t offer privacy and people usually are not allowed to disrobe when using them.

This is an important description. People may use this at beaches to rinse off sand and salt water, or at a swimming pool to rinse off chlorine. But the expectation is, soap is not used and people do not dis-robe. They simply rinse their self off or if they are in a pool chair, that also gets rinsed off.

While not delineated under F106.5 Defined Terms, outdoor rinsing showers are listed under Outdoor Constructed Features as an example. There are also technical requirements under 1011.2.1 of a 60″ x 60″ space with the space centered on the shower head which is located at the rear. And under 1011.7 where it states at least one hand-held shower spray with a 59″ minimum hose length where it can also be used in a fixed position within reach range of 15″ to 48″, or in high-vandalism areas, 2 fixed shower heads can be used. Controls are to meet requirements of reach range, one-handed use, and water flow to remain open for 10 seconds minimum. The 60″ x 60″ space is meant for someone to maneuver in their wheelchair while rinsing. Although not specifically stated, this space should be level with a 2.083% maximum slope and be located on an accessible route. A grab bar can be placed beyond the 60″ x 60″ space for those who are semi-ambulatory. The intent is not for someone to transfer out of their wheelchair, but rather rinse off the chair and their self, and some semi-ambulatory people can use the extra support of a grab bar.

The online ADA Guidelines which are issued by DOJ and DOT and were developed in cooperation with the US Access Board has provided the following in terms of rinsing showers which can be viewed here:

Are rinsing showers at swimming pools, beaches, and camping areas required to comply as showers?

Shower fixtures located outside bathrooms for use at swimming pools and beaches are not required to comply as showers. However, they must still meet applicable requirements for operable parts, including clear floor space and compliant controls within accessible reach range. The ABA Standards, which apply to federally funded facilities, include provisions for outdoor developed areas on federal lands. These provisions include requirements for outdoor rinsing showers (§1011.7) which can be consulted as a reference for other types of outdoor sites.

So, although rinsing showers are not listed as their own item under the ADA Standards, there is indeed a difference between them and a bathing shower which the 2010 ADAS does address. And with DOJ specifically stating that rinsing showers do not need to comply with bathing shower requirements, they are pointing the way to what can be used as equivalent.

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, FAIA, Architect, CASp 2025