Note: The following alert was distributed by the Division of the State Architect.
On Jan. 24, the California Building Standards Commission unanimously approved the Division of the State Architect’s proposed accessibility regulations for the 2013 California Building Code.
This historic update of California’s accessibility regulations integrated the most accessible provisions of the 2010 Americans with Disabilities Act (ADA) standards and the 2010 California Building Code into a single comprehensive code.
The approved regulations:
- used the 2004 ADA guidelines as model code
- used the format and organization of the 2010 ADA standards to enhance ease of use, compliance with both federal and state regulations, and to ensure certification by the United States Department of Justice
- included 171 amendments that incorporatedexisting California provisions that provide greater accessibility than ADA standards
- included 41 amendments that struck federal provisions that would have diminished California’s current level of accessibility.
The accessibility provisions are scheduled for publication by July 1 as part of the 2013 Code, which is effective of Jan. 1, 2014. The commission’s approval included limited amendments to clarify six specific provisions in DSA’s proposal.
One specific amendment that requires the attention of restaurant operators adjusted the location of accessible water closets from the adjacent wall or partition. A range of 17 inches to 18 inches will be allowed instead of 16 inches to 18 inches as originally proposed by DSA. The amendment changes emergency regulations that went into effect in August 2012.
Some background on this particular issue:
- The water closet centerline dimension was 18 inches when the 2010 Code first became effective in January 2011. This continued the provision in the prior 2007 edition of the Code and matched the equivalent requirement in the 1991 ADA Standards.
- The 18-inch dimension was changed to a range of 16 inches to 18 inches in the 2010 ADA Standards, which became mandatory nationwide March 15, 2012.
- On July 19, 2012 the Commission adopted emergency regulations amending the 2010 Code. One of these changes modified the 18 inch water closet centerline requirement to a range of 16 inches to 18 inches with an effective date of Aug. 1, 2012.
- During its approval of the DSA 2013 accessibility regulations, the commission affirmed the proposal to continue use of a range for the water closet centerline dimension. However, in response to public comments, the proposed range was adjusted to 17 inches to 18 inches. These technical requirements can be found in the adopted language at Section 11B-604 Water Closets and Toilet Compartments, 11B-604.2 Location.
- Current 2010 Coderequirements of 16 inches to 18 inchesremain in effect until December 31, 2013. The water closet centerline requirement will become 17 inches to 18 inches on Jan. 1, 2014 when the 2013 Code becomes effective.
Though centerline distances between 16 inches and 18 inches are allowed for new construction and path of travel improvements during alterations until the effective date of the 2013 Code, it is prudent to stay within the narrower range of 17 inches to 18 inches whenever possible.
Best practice is to specify a water closet centerline dimension at 17 ½ inches for the following reasons:
- This will minimize the need to make future incremental adjustments when toilet facilities are remodeled or updated after the 2013 Code becomes effective.
- Targeting the middle of the 17-inch-to-18-inch range complies with both the 2010 and 2013 editions of the code, and the 2010 ADA standards, while allowing for construction tolerances.
- Additionally, 16-inch-to-17-inch centerline distances will be covered by the exception allowing pre-existing non-compliant “path of travel” elements serving an area being remodeled to remain only while the 2013 Code is in effect.
- Use of the 16-inch-to-17-inch dimensions does not offer any benefit in terms of a reduced footprint or smaller area of the toilet and bathing facilities.
The final express terms of the DSA proposal, as approved and amended by the commission, will be posted at www.dsa.dgs.ca.gov.
For more information, contact the Division of the State Architect at email@example.com.