In This Issue
Fig. 28 Water Closets Not in a Stall
Proposed changes to TDLR Rules Chapter 68
What's next?
Volume VI  Number 10                October  2011
Even though the Federal Government adopted the 2010 ADA Standards as the law of the land, each State is allowed to have their own standards as well.  When faced with differences between State requirements and Federal requirements you must follow the most stringent guidelines on your projects.  In Texas we use the Texas Accessibility Standards that were adopted in 1994.  They are "equivalent" to the 1991 ADAAG but some areas have different and sometimes more strict requirements.  Below are some examples
Fig. 28 Water Closets not in a stall

 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. 

fig 28



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.

Proposed changes to TDLR Rules Chapter 68 

In an effort to reconcile the rules in Texas that differ with the 2010 Standards, a proposed changes to the TDLR Rules found in Chapter 68 Administrative Rules have been posted for comments.  Several exceptions have been eliminated because they have either been incorporated in the 2010 Standards exemptions, or they would not be allowed per the 2010 Standards. 


One section that is proposed to be eliminated is 68.104


68.104. Elements, Spaces and Accessible Routes at Fire Stations. (New section effective March 1, 2007, 32 TexReg 884)

At fire stations, common use spaces and elements accessed exclusively by fire-fighting personnel or other emergency responders are only required to be adaptable. Additionally, at multi-level fire stations, levels accessed exclusively by fire-fighting personnel are not required to be served by an accessible route. Public spaces and elements within these facilities must comply with all applicable technical standards. 


This section states that common use areas in fire stations exclusively used by fire fighting personnel will not be exempted any more.  Therefore any restrooms, kitchens or other spaces used by fire fighters exclusively will have to be accessible. 



A town hall meeting was held to discuss these changes and they can be heard in an archive on the TDLR website 


 What's next....


Remember that March 15, 2011 is when the new Standards became effective in the Federal level.  They will be mandatory on March 15, 2012. And each State will adopt it or not, at their discretion.


If you want to learn more about the new Standards, The ADA Companion Guide has the 2004 Guidelines with commentary and explanations throughout.


Upcoming CEU opportunities:


October 6 AIA Louisiana Convention in Shreveport from 10:30-Noon "Understanding the 2010 ADA Standards"


October 28th Texas Society of Architects Convention  in Dallas, Tx  8:30 a.m. and 2:00 p.m. "Making the Transition onto the 2010 ADA Standards"  Voted "Most Popular Class" of the 2011 TSA convention


Online course by the AIA National : The ADA and Urban Regeneration (as presented in the 2011 National convention)


 If you have any questions about these or any other topics, please feel free to contact me anytime.  

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714