Staff Analysis for Declaratory Statement Request DS2016-049

Issue: The Petitioner seeks clarification regarding Section 405.3.1 of the 5^th Edition (2014) Florida Building Code, Plumbing. Specifically regarding the placement of the water closet and where the compartment for that water closet is measured from.

Question: Is the build out on the left hand front corner of the tub considered a sidewall or an obstruction? If no, is the water closet compartment area measured from the centerline of the water closet to tub and centerline of water closet to vanity?

Background:

The Petitioner, Gregory Allen, President/CEO of Patriot Plumbing Corp of USA, seeks clarification involving Section 405.3.1 of the 5^th Edition (2014) Florid Building Code, Plumbing. The Petitioner would like to know if a build out on a left hand front corner of the tub is considered a sidewall or an obstruction. Also if no, would that water closet compartment area be measured from the centerline of the water closet to tub or water closet to closest vanity. This is concerning an installation in a development in Calusa Park of Nokomis, Florida. The petitioner’s company will be constructing more of these models in the future and wish to have clarification regarding the placement of the water closet and where the compartment is measured from.

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REFERENCES:

5^th Edition (2014) Florida Building Code, Plumbing

Chapter 4

405.3 Setting.
Fixtures shall be set level and in proper alignment with reference to adjacent walls.

405.3.1 Water closets, urinals, lavatories and bidets.
A water closet, urinal, lavatory or bidet shall not be set closer than 15 inches (381 mm) from its center to any side wall, partition, vanity or other obstruction, or closer than 30 inches (762 mm) center to center between adjacent fixtures. There shall be not less than a 21-inch (533 mm) clearance in front of the water closet, urinal, lavatory or bidet to any wall, fixture or door. Water closet compartments shall be not less than 30 inches (762 mm) in width and not less than 60 inches (1524 mm) in depth for floor-mounted water closets and not less than 30 inches (762 mm) in width and 56 inches (1422 mm) in depth for wallhung water closets.

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2012 International Plumbing Code, Code and Commentary

Chapter 4

Section 405.3.1 Water closets, urinals, lavatories and bidets.

“For the 2012 edition, Code Figure 405.3.1 was removed because the figure fell short of providing clear understanding of the requirements and, in some cases, made the requirements more confusing. In the context of this section only, bathtubs and showers are not considered to be “fixtures” but “obstructions” for which the minimum clearance dimensions from the indicated fixtures must be observed. Required minimum clearances in front of bathtubs and showers are not addressed in the code.

The requirements for placement and installation of plumbing fixtures for accessibility in toilet and bathing facilities “override” this sections’ dimensional requirements for “nonaccessible” plumbing fixture installation (see commentary, Section 404). A critical point that is often overlooked by designers and contractors is the accessibility requirement that the distance between urinal partitions for the wheelchair access urinal must be at least 36 inches (914mm). The centerline of the wheelchair accessible urinal must be at least 18 inches (457mm) from the face of e ach partition and not the minimum of 15 inches (381mm) as required for a non-accessible urinal.

Even though the code section is silent on exactly how the dimensions indicted in this section are to be measured the intent is that the dimensions are to be measured to finish surfaces of walls (including tile or other coverings) and to imaginary vertical planes located against the most exterior feature of a fixture or obstruction., The code is also silent on whether minor protrusions from walls such as paper product dispensers, hand dryers, cove moldings, diaper changing unites, display cases , vending machines and grab bars impact the measurement s discussed in this section.

The centers of the fixtures discussed in this section are not specific points on the fixtures, but a point which is “derived”. For example, a centerline of a lavatory bowl is typically ascertained by calculating the half way dimension between the widest outside dimension of the bowl. Given the difficulty in locating exact center of a fixture and a lack of coordination between trades establishing an inspection tolerance for the spacing and clearance dimensions required by this code section is next to impossible. However code officials will necessarily impart their own acceptance criteria (i.e. tolerances ) during an inspection in order to accept or reject a required clearance dimension. Therefore, designers of toilet facilities are cautioned against creating layouts, which require the building to the exact minimum clearance dimensions. A fixture layout having greater-than-the-minimum-clearance dimensions is inherently easier to building and results in far less inspection difficulties.

Note that all of the minimum dimensions stated in this code section may be overridden by the accessibility requirements of Chapter 11 of the IBC. See the commentary for Section 404. Good design practices for toilet facilities and bath rooms usually provide clearance in excess of the minimum requirements in order to provide for appealing aesthetics and user friendliness…”

CHAPTER 2 DEFINITIONS

201.3 Terms defined in other codes. Where terms are not

defined in this code and are defined in the Florida Building

Code, Building; Florida Building Code, Fuel Gas; Florida

Building Code, Mechanical; or the Florida Fire Prevention

Code, such terms shall have the meanings ascribed to them as

in those codes.

201.4 Terms not defined. Where terms are not defined

through the methods authorized by this section, such terms

shall have ordinarily accepted meanings such as the context

implies.

Definition of “obstruction” by Merriam-Webster

Something that blocks something else and makes it difficult for things to move through

The condition of being blocked so that things cannot move through easily

The act of making it difficult for something to happen or mover forward

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Staff Recommendation:

Answer: The answer is “Yes”. As per Section 405.3.1 of the 5^th Edition (2014) FBC, Plumbing, the build out in question is considered an obstruction/sidewall and 15-inches of clearance would be required.