Appeal 35088

ADAG/ANSI 117.1 Section 604.5.2

The rear wall grab bar [at an accessible water closet] shall be 36 inches long minimum and extend from the centerline of the water closet 12 inches minimum on one side and 24” minimum on the other side. See Exhibit A for ADAG 2010 diagram.

In response to the tank height of the vandal resistant toilets on this project, use of ADAG 2010 Section 604.5.2, Exception #2 is proposed with the rear grab bar shifted to the open side of the water closet in lieu of being above the toilet tank.

In alignment with ADAG 2010 and ANSI 117.1-2017 Section 604.5.2, Exception #2, the rear grab bar is prosed to be shifted to the open side of the toilet area to avoid a conflict with the toilet tank and maintain the grab bar maximum installation height of 36”. This condition will apply to two accessible toilets in single-user toilet rooms. The side grab bars are to be installed in accordance with code requirements. The lavatory sinks are located outside the toilet rooms providing maximum clearance and access to the toilet within the room. See Exhibit A for proposed room elevation and plan.

604.5.2 Exception #2 Language:
Where an administrative authority requires flush controls or flush valves to be located in a position that conflicts with the location of the grab bar, then the rear grab bar shall be permitted to be split or shifted to the open side of the toilet area.

This project is intended to be utilized as an emergency shelter under ORS 197.782. As such, vandal resistant toilets are to be installed in the restrooms, including the accessible stalls. The height of the vandal resistant toilet tank conflicts with the code required installation height of the rear grab bar. To provide equivalent access, shifting the rear grab bar in alignment with ADAG/ANIS 117.1 Section 604.5.2, Exception #2 will provide equivalent transfer options to access the water closet. Additional factors influencing the proposed alternative design include:
• The building water supply is insufficient to serve flush-valve type toilets. So, tank-type toilets are the only option for this facility without a costly upgrade to the water meter size.
• There are limited manufacturers of vandal resistant tank-type toilets as these are for a specialty market. The available products have taller tanks to incorporate vandal resistant access to the tank and other components. To maintain required grab bar clearances, the top of grab bar would need to be installed at 38.25”, exceeding the 36” maximum by code.
• In accordance with a 2016 study by the Georgia Institute of Technology, "Analysis of the Effect of a Rear Wall Grab Bar Configuration on the Fall Risk Associated With Toilet Transfers in Older Adults with Mobility Impairment", the rear grab bar was associated with a more challenging transfer than use of the side grab bar alone due to the need for additional stretching across the length of the toilet. Therefore, the rear grab bar is less utilized than the side grab bar.
• Research by the Architect included observations of online videos of individuals demonstrating use of the rear grab bar to transfer onto the toilet; this included demonstrations by Occupational Therapists. In these videos, all observed use included grasping the rear grab bar approximately 6” to 12” away from and on the open side of the toilet. The proposed installation on this project maintains the grab bar in the location typically used in the observed demonstrations.