|Plumbing fixtures and Alterations|
Here is a question I've been asked recently several times:
"If I'm just changing out finishes and plumbing fixtures in an existing restroom, do I have to bring the entire restroom up to compliance?"
This is a complicated question. In the ADAAG and TAS there is a definition for "alterations" which states:
[Alteration is a] A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. ...... Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.
Notice the last sentence where it describes the parts of a "construction" project that are considered normal maintenance. The changes in finishes and even the mechanical and electrical will be considered maintenance and will not require any upgrades to the room. But plumbing fixtures are not listed; therefore if you are replacing plumbing fixtures, those will have to comply.
Replacing a single fixture would only require that the new fixture comply to the maximum extent feasible based on TAS 4.1.6(1)(b) and the following provisions of TAS 4.1.6(1)(j):
" Any elements or features of the building or facility that are being altered and can be made accessible shall be accessible within the scope of the alteration"
For example, the maximum extent feasible at the time of the replacement of a damaged water closet may require compliance with the height, flush valve, and grab bar requirements of TAS 4.16.
However, removing all fixtures in a toilet room would trigger compliance with TAS 4.1.6(1)(c) and the entire space would be required to comply.
This TAS standard was probably implemented because an empty space is an opportunity to achieve accessibility.
|On the Lighter Side|
An accessible entrance to a commercial facility is required....This one is not too accessible!