New Jersey’s barrier-free subcode was designed to work in conjunction with the Americans with Disabilities Act and ANSI A117.1-2003, the International Code Council’s standard for accessibility, to ensure accessibility in new construction and renovations.

Single-occupant restrooms in private office spaces have some flexibility for the permit process in that they must be adaptable to the provisions of the barrier-free subcode, but not necessarily built to them for permit.

Exceptions for Single-Occupant Restrooms

According to the governing code (ICC/ANSI 117.1-2003 Chapter 6. Plumbing Elements and Facilities), a facility must meet an exception from each section below, or else it must comply with the standard. All items not required per these exceptions must be adaptable to meet the standard later if necessary, where indicated.

Toilet or bathing facilities for a single occupant, which are accessible only through a private office and are not for public or common use, may check for the following exceptions:

603.2.3 – Clearances: Door Swing

Exception #1: … permitted to swing into the clear floor space, provided the swing of the door can be reversed to meet Section 603.2.3.

Exception #2: … clear floor space complying with Section 305.3 is provided within the room beyond the arc of the door swing.

Benefit: Doors can swing into the restroom.

604.3.2 – Water Closets and Toilet Compartments: Overlap

Exception (Per UCC 5:23-7.2(b)10): … a lavatory complying with Section 1033.11.5 shall be permitted on the rear wall 18” minimum from the centerline of the water closet where the clearance at the water closet is 66” minimum measured perpendicular from the rear wall.

Benefit: Required fixtures clearances in the restroom can overlap.

604.4 – Water Closets and Toilet Compartments: Height

Exception: … shall not be required to comply with Section 604.4

Benefit: Water closet outside of the standard 17” to 19” heights can be used.

604.5 – Water Closets and Toilet Compartments: Grab Bars

Exception #1: … not required, provided reinforcement has been installed in walls and located so as to permit the installation of grab bars complying with Section 604.5.

Benefit: Grab bars are not required to be installed; however, the wall must be reinforced to support future installations.

606.2 – Lavatories and Sinks: Clear Floor Space

Exception #2: The requirement for knee and toe clearance shall not apply to a lavatory in a toilet and bathing facility for a single occupant, accessed only through a private office and not for common use or public use.

Benefit: Cabinetry or other assemblies below a lavatory or sink can be installed without meeting knee and toe clearance requirements.

606.3 – Lavatories and Sinks: Height

Exception: … shall not be required to comply with section 606.3.
Benefit: Lavatories and sinks are not required to meet the 34” maximum height.

If you have questions or comments on this topic, contact the New Jersey office of Milrose Consultants.