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Restroom Signage and the ADA

Restrooms with non-compliant pictogramCircles, Triangles, Men’s, Women’s…what’s the deal with ADA restroom signage? The issue regarding Restroom sign requirements recently became the topic of discussion with a group of CASp experts. We’ve all seen bad Restroom signs and we’ve all seen (what we think) is good Restroom signage. Do you wonder how often restroom signage has been referred to in recent lawsuits?…Once. That’s right, for all of the complaints we’ve reviewed in the past 6 months, we’ve only seen it mentioned once.

Regardless of that statistic, the ADA and CBC include restroom signage requirements and must be included at facilities. Based on a discussion with CASp’s there are a couple of ways to look at the requirement for restroom signs vs. the recommended way of signing restroom. When we look at “requirements” we need to look at the ADA law and guidelines as well as the California Building Code.

What the ADA Says

When we look to the ADA requirements, we start in the “scoping” sections (the 200’s) to see “what” is required for accessibility. These sections will tell us IF something is required.

Section 216.2 “Room Designation Signs”
Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2, and 703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have text descriptors complying with 703.2 and 703.5.

From this section, IF signs are provided that identify permanent rooms and spaces, the sign must meet the requirements stated in 703.1, 703.2, and 703.5. IF pictograms (like the stick figure man and woman) the graphic must meet the requirements in 703.6 and have text explanations complying with 703.2 and 703.5.

216.08.a – Toilet Rooms and Bathing Rooms
Where existing toilet rooms or bathing rooms do not comply with 603, directional signs indicating the location of the nearest toilet room or bathing room complying with 603 within the facility shall be provided. Signs shall comply with 703.5 and shall include the International Symbol of Accessibility complying with 703.7.2.1.

The section 216.8 deals specifically with toilet and bathing room signage. The first group of sentences deals with needing a directional sign showing which way to the nearest accessible restroom. This is required if the restroom is NOT accessible. So IF your restroom is accessible, no directional sign is needed.

216.08.b – Toilet Rooms and Bathing Rooms
Where existing toilet rooms or bathing rooms do not comply with 603, the toilet rooms or bathing rooms complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.

Similarly, IF your restroom is NOT accessible, you must add the ISA (wheelchair symbol of accessibility) to the restroom that is accessible.

216.08.c – Toilet Rooms and Bathing Rooms
Where clustered single user toilet rooms or bathing facilities are permitted to use exceptions to 213.2, toilet rooms or bathing facilities complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1 unless all toilet rooms and bathing facilities comply with 603.

Lastly, when a group of uni-sex restrooms are provided there is an exception in the ADA that clarifies how many of the provided uni-sex restrooms MUST be accessible

213.2.e4 – Exception
Where multiple single-user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603.

So, back to 216.08, IF only 50% of the clustered uni-sex restrooms are accessible, the ones that are accessible MUST have the ISA symbol at the door. IF all of the clustered uni-sex restrooms are accessible, no symbol is required.

In summary, the only requirement for providing signs at the restrooms, is IF some are accessible and some aren’t, the ISA must be posted at the door.

What the CBC says

Looking at the same scoping sections in the California Building Code, we find very similar requirements.

Section 216.2 “Room Designation Signs”
Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2, 703.3 and 703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have text descriptors complying with 703.2 and 703.5.

The only difference is the addition of a requirement to meet section 703.3, which refers to Braille letters on signs.

The CBC adds two parts to the 216.08:

216.08.d – Toilet Rooms and Bathing Rooms
Doorways leading to toilet rooms and bathing rooms complying with 603 shall be identified by a geometric symbol complying with 703.7.2.6.

This section does not include the IF statement seen in the ADA sections. This requires that doorways leading to restrooms, MUST have a geometric symbol posted on the door. It’s also important to note that the required “geometric symbol” does not say anything about a man or woman symbol, text, braille, or ISA symbol on the symbol. Just the symbol.

216.08.e – Toilet Rooms and Bathing Rooms
Existing buildings that have been remodeled to provide specific toilet rooms or bathing rooms for public use that comply with these building standards shall have the location of and the directions to these rooms posted in or near the building lobby or entrance on a sign complying with 703.5, including the ISA complying with 703.7.2.1

Lastly, the CBC requires a sign that indicates where remodeled restrooms are located in existing buildings.

To summarize the sign requirements (scoping) in the CBC, the only requirement for the restrooms, specifically, are the geometric symbols on the doors. There is no mention (read requirement) for the MEN, WOMEN, man symbol, woman symbol.

This sketch would therefore represent “compliant” signage for accessible men’s and women’s restrooms. Without Googling it, which one would you walk into?Restroom doors with just a blue triangle and blue circle

The second sketch would be considered compliant signage if two unisex restrooms are provided and both meet accessibility requirements inside
Two unisex restrooms with just geometric symbols

What DSA recently said

In the discussion with other CASp’s, it was mentioned that DSA (California’s State Architect) provided an explanation that the code (CBC) doesn’t REQUIRE the restroom sign next to the door, just the geometric symbol. Hopefully you can see from the code snippets above this same conclusion.

The discussion became…lively…when, as CASp’s, we discussed whether or not our CASp Reports, or Accessibility Inspections should indicate that a restroom door with just a triangle on the door is “compliant” or not. Some offered, that their reports state that a restroom without a MEN or WOMEN sign next to the door is a non-compliant finding. Others, cited the code text and believed that the reports must be based clearly on the guidelines and code.

What we should say to businesses

Restroom doors with geometric symbols and tactile signsSome CASp’s feel that as “Experts” in the California ADA field, it is our responsibility to make sound recommendations to business owners looking to be more accessible. In my opinion, this sentiment is shared with many CASp’s. However, when we are charged with providing a report that is based on the ADA Guidelines and CBC Accessibility Code, the CASp must be diligent to make findings based on code and not personal preference or “best practices”. It is not wrong to inform a business owner, that IF, they wanted to make using the restroom much easier to their patrons and wanted to add a MEN or WOMEN sign on the door, those signs MUST meet certain tactile requirements.

 

David HornRestroom Signage and the ADA