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Building Code Issues: All Gender Restrooms

Kerwin Lee, AIA CASp

Kerwin Says: (with the assistance of Steve Winkle, FAIA)

I recall when I first got started in architecture, my first task was to design restrooms for a project. Perhaps your start was the same. One quickly learns what the criteria is; providing restrooms are always essential to any project.

Something new has been added to this design, at least when it comes to signage and perhaps will become a whole new way of designing restrooms. Assembly Bill 1732, passed by the assembly and signed into law by the Governor on September 29, 2016 became effective on March 1, 2017. This law requires all “single user toilet facilities” to have special signage.

The problem is there is nothing in the code, including the current CBC 2016, that addresses this to meet the law’s requirement. The only guidance at this time is found in a bulletin issued by DSA on January 19, 2017. This bulletin, BU 17-01 is available through the following link:

The bulletin, which is supplemental information to any building standards or code, only applies to DSA projects: public schools, state buildings and projects under DSA’s authority. So what are we designing to? AB 1732 is law and even without specifics on how to comply, we have an obligation to. We can use DSA’s bulletin as a guideline. The best way is to talk with the Authority Having Jurisdiction (AHJ) for your project on when and how to comply. The bill lacks specifics or at least clarity as to when it is required. Does this apply to all restrooms that exist or new and/or remodeled only?

According to DSA’s bulletin, they recommend that the symbol on the door be a triangle within a circle. They say that no pictogram is required and no other signage (text) is required. If you or the owner chooses to have a text sign, it should say one of the following: “ALL-GENDER RESTROOM,” “RESTROOM,” or “UNI-SEX RESTROOM,” The text with braille needs to comply with the code for all accessible signs. It is best to stay away from any other text or having any pictogram associated with the symbol or text sign. One can look through the debate online on this subject and some of the suggested signs/symbols to be used-many are politically incorrect.

Here is one of the problems you will be facing for complying with the code, “Fixture Count.” If all single user facilities are now all gender, how is it counted in tabulating the number of required fixtures for a facility or building for compliance with Chapter 29?

The biggest question is compliance with Section 2902.2: separate sex facilities. Separate sex facilities are a fairly recent standard, introduced in the mid-19th century. It was associated with having women in the work force in factories, but that is another subject of discussion. Add to this the complexity of urinals and how they are counted.

There may be an opportunity for some creative and new approaches to design for restrooms. For an A-2/restaurant with ten or less occupants, a single unisex facility would comply. For an occupant load of 25 or less, two fixtures or two single-user facilities are required. For an occupant load of 49 or less, three fixtures are required. A possible solution could be as diagramed on the right with two accessible single-user facilities and a single water closet in the third. The two lavatories would comply with the minimum required number. This design would require an Alternative Materials and Method Request (AMMR) because it does not strictly comply with the code, but may comply with the intent. Some social norms may also be changed here.

The building standards or codes do need to be adjusted to address all of these social changes. In the mean time, we all need to proceed with caution on how we address this. We also need to recognize that because there are no statewide code standards this will be in the hands of local jurisdictions and there may be different requirements/interpretations in different jurisdictions.

Drawings courtesy of the City of Oakland Building Department.