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Single Restrooms – What needs to be done?

Let’s say you have single accommodation restrooms in a pre-ADA building which is a place of public accommodation. There are several items to consider. What you end up doing depends on whether or not you have done any alterations to the building and how much you have spent or plan on spending. And do realize, these are minimum considerations.

• If you are not doing nor have you done any alterations to the building since January 26, 1992 you would still need to remove barriers that are Readily Achievable. Depending upon the space and your finances since 1992, this could mean widening doors or if not feasible installing offset hinges, removing door knobs and installing lever hardware, putting in grab bars, insulating pipes and rough edges under the lavatory, putting in a raised toilet seat, lowering accessories to be within compliant reach ranges, and a number of other items including signage. But do remember this is an ongoing task and should be revisited annually until the restroom complies as much as possible.
• If you are doing or have done an alteration since January 26, 1992 and it is under the Valuation Threshold ($161,298 for 2018) then you need to spend an additional 20% of the construction budget on Path of Travel obligations to the space being altered which also includes restrooms that support that altered space.
• If your alteration is over the Valuation Threshold, and this is calculated over a 3 year period, if you have separate men’s and women’s restrooms, then you are required to have at a minimum, both restrooms accessible. If you have multi-user restrooms and there is not enough space to make them both accessible, you will need to provide one single-user restroom for each sex in the same general area as the multi-user. If this is not technically feasible then one accessible unisex restroom is required to be installed per altered floor.

Related Article: Single User Toilet Rooms in California

If you started out with 2 single accommodation restrooms, one men and one women, but neither were accessible, per the first scenario you would need to remove barriers in both the men’s and women’s restroom that are Readily Achievable. Per the second and third scenarios above, you would need to remodel both single-user restrooms to make them accessible or if this is not technically feasible, convert both to unisex restrooms making one fully accessible and the other as accessible as possible. If you are under the Valuation Threshold, you do as much as possible, but if your construction budget is over that amount, and it changes annually, then you will need to have one accessible restroom for men and another for women or if it is technically infeasible, then at a minimum, provide one unisex that is accessible. And one other item to note – this is also true for shower or bathing rooms as well.

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.

© 2012 Janis Kent, FAIA, Architect, CASp revised October 2018