Universal washrooms shall meet a series of design requirements related to the placement of the fixture, sink, door, grab bars, clearances, etc. These requirements are listed in Article 3.8.3.12. of NBC 2015 (amended Quebec).

Is Clear Floor Space Encroachment Allowed?

Many designers question the 1 500 mm diameter clear floor space required inside universal washrooms to allow a wheelchair to turn in an open space [3.8.3.12.(1)(i)]. The intent of this Clause does not specify whether the door may encroach on this clear floor space, nor does it specify whether this also applies to plumbing fixtures (toilet, sink) and accessories (grab bars, garbage cans, changing table, etc.).

Since the publication of a user’s guide to barrier-free design Standards in 2006, based on the requirements of the NBC 1995 (amended Quebec), most designers have realized that it is acceptable for equipment such as the sink to encroach into the clear floor space. Indeed, the illustration provided in the guide showed a sink encroaching on the clear floor space. A similar illustration was included in the 2010 update of this guide, based on the NBC 2005 (amended Quebec).

During the year 2021, Technorm became aware of corrective notices issued during inspections by the Régie du bâtiment du Québec (RBQ) regarding the clear floor space of universal washrooms. The fact that doors or accessories encroach on the 1 500 mm clear floor space was considered a deficiency.

Right On Time

Technorm received a letter from RBQ in early March 2022, indicating that the official interpretation on clear floor space encroachment in barrier-free washrooms had been updated. This update was made following consultations on accessibility Standards in which RBQ participated with other Canadian jurisdictions and Standards organizations.

The following is an excerpt from that communication:

“RBQ considers that the design of the clear floor space allows for the encroachment of a door into its clear space. This applies to the universal washroom as well as to the water-closet stalls and washrooms in dwellings.

In addition, this interpretation applies to the encroachment of equipment or furnishings on the clear floor space if the minimum height clearances required by regulation are provided for knees and feet such as those applicable to sinks in Section 3.8.3.11.(1)(c) of the Building Code 2010.”

(Our translation)
 

New Guide on Building Accessibility

RBQ also published on March 25, 2022, a new guide on building accessibility, based on the NBC 2015 (amended Quebec), which is in force since January 8, 2022.

Regarding the clear floor space, this guide suggests, as a guideline, that where possible, there shall be no doorways or encroachments into the clear floor space to improve accessibility for people with disabilities. Technorm strongly agrees with this statement.

In our opinion, if the door swing encroaches on the clear floor space of a washroom, there still needs to be enough space (e.g., 750 mm x 1 200 mm) for the wheelchair to fit in without interfering with the door swing. Otherwise, the user will not be able to close the door after entering the washroom.

Learn More

Want to learn more about building accessibility requirements? Technorm is offering a new program in the spring of 2022. Check out our training courses

Questions about this topic? Feel free to contact the author of this article!

By: Valérie Lorrain, Architect, Head of Expertise – Codes, Standards, and Fire Safety

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