Appeal 35033

OSSC 1110.2 Toilet and bathing facilities — Exception 3

Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50 percent, but not less than one room for each use at each cluster, shall be accessible.

Allow calculation of the required 50% accessible single-user toilet rooms across the entire floor rather than within each defined “cluster.”

In other words, instead of providing 50% accessible rooms within each cluster, we propose meeting 50% accessible rooms for the floor as a whole.

The project provides a total of 6 single-user toilet rooms, of which 3 are fully accessible, and are proposed to meet requirements of Chapter 11 and ICC A117.1.

A floor plan documenting the accessible rooms, locations, and routes of travel is included for review. The accessible rooms are centrally located, on an accessible route, and fully serve the building occupants without restricting access or increasing travel distance.

This project is a renovation of an existing building that includes new restrooms, upgraded fire sprinkler protection, accessibility improvements, and significant life-safety enhancements. While the project substantially improves accessibility, the strict application of the “cluster” requirement in OSSC 1110.2 creates a disproportionate hardship due to the existing building configuration. The restroom vestibule area is compact and constrained by structural walls, plumbing locations, and required clearances, leaving no practical way to enlarge or reconfigure the rooms without extensive demolition, major relocation of plumbing infrastructure, and a substantial loss of usable square footage. The building is occupied by a non-profit tenant for whom this limited floor area is essential to ongoing program operations; every square foot in the vestibule area directly supports mission-critical needs.

Despite these constraints, the intent of the code—ensuring equitable and convenient access to accessible toilet rooms—is fully met. Providing 50% accessible restrooms across the floor creates no reduction in accessibility. The accessible rooms are located on a direct, unobstructed route and provide equal, convenient access for all occupants, including individuals with disabilities.

a. The intent of the code is met through equivalent accessibility
OSSC 1110.2 Exception 3 seeks to ensure equitable access where multiple restroom choices exist. With three accessible single-user restrooms on the floor, distributed so that at least one accessible option is always in close proximity, users with disabilities have access equivalent to what would be provided under a strict cluster-based calculation.

The combination of:
• Two accessible rooms serving the Sanctuary zone
• One accessible room on the same level near the Chapel
• Clear signage and a short, direct circulation loop

together provide the functional equivalent of accessible choices within the same restroom zone.

b. The Chapel accessible restroom is part of the same functional “restroom zone”
Although the restrooms are not technically a “cluster” by definition, the Sanctuary and Chapel areas share:
• The same floor
• The same assembly occupancy
• A very short distance within a compact floorplate
• Unobstructed circulation paths

Given these conditions, the Chapel accessible restroom effectively serves users in the Sanctuary zone without disadvantage or meaningful increase in travel distance.

This approach is consistent with Portland BDS precedent, such as Appeal ID 18599, in which the City approved restroom accessibility alternatives in existing buildings when equivalent access was maintained despite structural and spatial limitations.

For these reasons, we respectfully request approval of this alternate method. The proposed solution meets the intent of the code, maintains full accessibility for all users, and avoids disproportionate impacts on the use of an existing, space-constrained building occupied by a non-profit tenant.