Appeal 33538

2902.1, 1110.2, Ex. 3

OSSC 2902.1. Plumbing fixtures are required to be provided based on the total occupant load of the building. Portable plumbing fixtures are not specifically addressed in the OSSC or OPSC.
OSSC 1110.2, Ex. 3. Where multiple single-user toilet rooms are clustered in a single location, at least 50% of the toilet rooms in the cluster are required to be accessible.

OSSC 2902.1. Provide portable plumbing fixtures for only the additional occupant load being added to the field during a Concert event.

OSSC 1110.2, Ex. 3. Provide accessible toilet rooms such that a minimum of 5% of the toilet rooms will be accessible, as permitted by the 2010 Americans with Disabilities Act (ADA) Standards.

Apart from the increased occupant load proposed on the field during a concert, the occupant load of the building is not increasing as a result of this project. Refer to Sheet G004 for an occupant load comparison that shows an overall decrease in occupant load, when compared to the previous 2017 project (see Appendix A). Portable plumbing fixtures are proposed to be provided on the field for concert events, based on the increased occupant load. The existing projects show a total field occupant load of 5,000. This project proposes a maximum of 12,622 occupants on the field, which represents an increase of 7,622 occupants. Plumbing fixtures are not proposed to be provided for the existing occupants, as they are already provided with existing fixtures. Plumbing fixtures are proposed to be provided for the 7,622 added occupants.

Due to the difficulty of providing permanent restroom facilities for the additional occupant load, and because the occupant load (and required fixture count) will vary for each event, portable facilities are proposed to be provided for each event. A sample layout of the portable facilities is shown on Sheet ES-101.C (see Appendix A). The layout is provided for informational purposes only, to demonstrate one option for locating the facilities. In this layout, single-user toilet rooms, hand washing stations, and drinking fountains are proposed.

Section 213.2 of the 2010 ADA Standards mirrors the requirements of Section 1110 of OSSC, as seen in Figure 1 below.

Figure 1: Comparison of ADA and OSSC Requirements

Each have the same exception for reducing the percentage of required accessible toilet rooms from 100% to 50% when multiple single-user toilet rooms are provided in the same area of the building. However, this exception is referring to permanent facilities located in a building and is not necessarily envisioning outdoor events with temporarily elevated occupant loads. For this reason, the ADA includes an additional exception specifically for portable toilet units. This additional exception (Exception 3) allows only 5% of the portable toilet units to be accessible. The accessible portable toilet units provided for this project will be provided with the International Symbol of Accessibility (ISA) in accordance with ADA Section 703.7.2.1.

Portable Toilet Units
The required number of portable toilet units is based on the required number of male water closets plus the required number of female water closets, using the following ratios from OSSC Table 2902.1:
• Male water closets: 1:75 (first 1,500) + 1:120 (over 1,500)
• Female water closets: 1:40 (first 1,520) + 1:60 (over 1,520)

For the maximum permitted 12,622 occupants on the field:
• Existing 5,000 occupants are provided with existing facilities
• New 7,622 occupants are being provided with portable toilet units, as follows:
o Male occupants: 3,811
o Female occupants: 3,811
o Male water closets required: 40
o Female water closets required: 77
o Total water closets required: 117
o Total portable toilet units required: 117
o Accessible portable toilet units required (5%): 6
o Non-accessible portable toilet units required: 111

The above process will be followed for events with a field occupant load less than 12,622 and may results in fewer required fixtures.

Portable Hand-washing Stations
The required number of portable hand-washing stations is based on the required number of male lavatories plus the required number of female lavatories, using the following ratios from OSSC Table 2902.1:
• Male lavatories: 1:200
• Female lavatories: 1:150

For the maximum permitted 12,622 occupants on the field:
• Existing 5,000 occupants are provided with existing facilities
• New 7,622 occupants are being provided with portable hand-washing units, as follows:
o Male occupants: 3,811
o Female occupants: 3,811
o Male lavatories required: 20
o Female lavatories required: 26
o Total lavatories required: 46

The above process will be followed for events with a field occupant load less than 12,622 and may results in fewer required fixtures.

Portable Drinking Fountains
A single “high/low” portable drinking fountain is proposed on the field. OSSC Table 2902.1 requires a minimum of one drinking fountain per floor. OSSC 1110.5.1 requires at least one drinking fountain complying with the requirements for people who use a wheelchair and one drinking fountain complying with the requirements for standing persons.

The proposed design provides the code-required number of plumbing fixtures (water closets, lavatories, and drinking fountains) for the additional occupant load on the field. Since the code does not provide provisions for portable plumbing fixtures, this alternative design is proposed to allow these additional plumbing fixtures to be provided during a concert event. If permanent restroom facilities were to be required, the current infrastructure would not realistically be capable of providing new permanent facilities. Therefore, temporary facilities are proposed on the field. A benefit of this design is that the number and location of portable plumbing fixtures can be adjusted to match the field occupant load of each unique event. Additionally, this appeal requests to utilize the ADA requirement for number of accessible single-user restrooms, to align with other portions of the Stadium where a minimum of 5% of the water closets in multi-user restrooms are required to be accessible. If this alternative design was not proposed, then one-half of the portable restrooms would be required to be accessible. The proposed design is consistent with the Federal accessibility requirements of the 2010 ADA Standards and meets the intent of the code.