For water closets not found in a stall, like in Unisex restrooms, Figure 28 is used to locate water closets. Fig. 28 is shown below.
This figure shows a plan view of three options for arranging the water closets and the lavatories that are on the same wall. The figure shows the amount of clear floor space required for the water closet depending on the approach. It also shows in plan the relationship of a lavatory adjacent to the water closet. The first two figures are no longer accepted in the 2010 ADA Standards. This means that a lavatory will not be able to be located in the clear floor space of the water closet in restrooms constructed after the mandatory compliance date of the 2010 ADA Standards. But in Texas we are still under the 1994 TAS which is equivalent to the 1991 ADAAG, and therefore it is still acceptable until March 15 2012, when the more stringent ADA Standard will be mandatory.
The first two figures show a dashed line which is the plan view of half of a lavatory located on the same wall as the water closet. In the ADAAG it only shows the plan view but does not explain the section view. In Texas, a technical memorandum was issued in 2000 (TM 00-02) explains what is acceptable below the lav. ** BEWARE, there were two memorandum issued but only the one on the website is correct. This Memo explains that in order for the lavatory to be located in the clear floor space of the water closet as shown on Fig. 28 (36" away from the side wall), the lavatory must have the same profile as Fig. 31 (shown below taken from ADAAG Manual)
This means that in Texas the lavatory must not have legs or side panel that touch the ground unless it is 60" away from the side wall of the water closet. A wall hung lavatory or vanity with a support that allows the clearances shown on Fig. 31 is the only lavatory that is acceptable to be in the clear floor space of the water closet. This allows maneuvering onto the water closet by using the under side of the lavatory.
In existing restrooms, only those who meet this requirement in Texas will be able to be considered a safe harbor per the DOJ's definition. This means that if the restroom follows the clearances shown on the 1991 ADAAG Fig. 28 and TDLR's TM 00-02, then the existing restroom will be acceptable as is (even though it does not meet the 2010 ADA Standards). This restroom configuration will be acceptable until such time that the restroom is renovated and then it must be upgraded to meet the 2010 Standards.