Is there an Exception for Private Bath for ADA Compliance

Recommended Posts

I have a client that wants a private half bath for her office.  The drawings submitted to the state Fire Marshall came back stating that the private bath had to be ADA compliant.  Is there an exception for a private bath?

This is the excerpt concerning a private half bath?


ADA-ABA:603 and 604 Toilet rooms for a single user accessed through a private office shall comply with the following: -

- 603.2.1 Provide a 5’ turning radius or T-shaped turning space complying with 304 within the room (located outside of any stalls and clear of all fixtures.)-

- 604.2 The centerline of the water closet shall be 16 inches minimum to 18 inches maximum from the nearest adjacent wall; and- 604.3.1 Provide a clearance around the water closet that complies with Figure 604.3.1. Clearance around a water closet shall be 60 inches minimum measured perpendicular from the side wall and 56 inches minimum measured perpendicular from the rear wall. (NOTE: As per 604.3.2 No other fixtures or obstructions shall be located within the required water closet clearance.)

- 604.5 Provide sufficient reinforcement in walls as to permit the future installation of grab bars complying with 604.5; and (Provide blocking within the walls to accommodate a future 42" long grab bar adjacent to the toilet and a 36" long grab bar behind the toilet.)

- 404.2.3 Door openings shall provide a clear 32 inches minimum; and

- 603.2.3 Doors shall be permitted to swing into the clear floor space or clearance provided the swing of the door can be reversed to comply with 603.2.3.- Maneuvering clearance at the door shall be such that a person with a disability can approach, enter and exit the room.


Link to comment
Share on other sites

On 3/17/2024 at 4:57 PM, 5FT-20Designs said:

Is there an exception for a private bath


Assuming this is a commercial not residential project.  Looks like the building official cites the relevant code section in first comment.  I'd start there and see if there is an exception listed. 


Link to comment
Share on other sites

In my experience, as long as an accessible bath is provided, a private bath need not be designed to be accessible unless it provides a facility that isn't available elsewhere. For example, I redesigned the corporate offices of a local business that occupy a ground floor tenant space. The project included a fitness room and private bath for the CEO. An accessible bathroom was located down the hallway, open to everyone for use. Because his private bath included a shower, and no shower was provided elsewhere, the shower had to be accessible and therefore required grab bars and an area for a turn circle in the bath. 


If your private bath doesn't include elements not available elsewhere and requiring accessibility, it is a bathroom like any other in the space. An accessible bath elsewhere in the space would satisfy the ADA. Without reviewing the plan correction report myself, I am inclined to believe that the plan reviewer has made an error and is incorrectly citing code.

Link to comment
Share on other sites

Please sign in to comment

You will be able to leave a comment after signing in

Sign In Now