This proposed change to explanatory Note A-3.7.2.2.(1) clarifies the NBC requirement for a minimum number of water closets in buildings and how the NBC addresses gender-neutral washrooms.
Related Code Change Request(s):
CCR 1431
Problem
The NBC requires that a certain minimum number of water closets be provided in buildings based on occupancy type and the expected proportion of males and females in the occupant loads. However, the wording of the requirements could be misinterpreted to mean that separate washrooms for males and females must be provided. Several Code enquiries have sought clarification on how “gender-neutral” washrooms are considered in the NBC and if they are allowed since enforcement issues have also been raised.
While washrooms have historically been separated according to gender, it is becoming more common to have non-gender-specific washroom spaces.
This proposed change to explanatory Note A-3.7.2.2.(1) clarifies that the NBC only requires that a minimum number of water closets be made available to the building’s occupants.
Additionally, the NBC 2020 introduced new requirements on barrier-free access to floor areas and on universal washrooms wherever washrooms are provided on barrier-free storeys. Since universal washrooms are not gender-specific and can be used by anyone, the wording of the existing explanatory Note to Sentence 3.7.2.2.(1) is now inaccurate.
Justification
The NBC requires a minimum number of water closets in buildings, but does not require that washrooms be separated according to gender. This proposed change to explanatory Note A-3.7.2.2.(1) clarifies this point, with a view to helping designers to create acceptable washroom spaces and authorities having jurisdiction to approve their designs.
With the introduction of new accessibility requirements in the NBC 2020, Note A-3.7.2.2.(1) of the NBC 2020 is no longer accurate. The explanatory Note is being reworded accordingly to reflect the Code provisions.
EXISTING PROVISION
NBC20 Div.B 3.7.2.2. (first printing)
3.7.2.2.Water Closets
1)Except as permitted by Sentence (2), water closets shall be provided for each sex assuming that the occupant load is equally divided between males and females, unless the proportion of each sex expected in the building can be determined with reasonable accuracy. (See Note A-3.7.2.2.(1)EXISTING PROVISION A-3.7.2.2.(1).)
2)Both sexes are permitted to be served by a single water closet if the occupant load in an occupancy referred to in Sentence (4), (8), (10), (11), (12)or (14) is not more than 10.
3)Urinals are permitted to be substituted for two thirds of the number of water closets required by this Article for males, except that if only 2 water closets are required for males, one urinal is permitted to be substituted for one of the water closets.
4)Except as permitted by Sentences (2), (5)and (6), the number of water closets required for assembly occupancies shall conform to Table 3.7.2.2.-A.
Table 3.7.2.2.-A Water Closets for an Assembly Occupancy Forming Part of Sentence 3.7.2.2.(4)
Number of Persons of Each Sex
Minimum Number of Water Closets
Male
Female
1 - 25
1
1
26 - 50
1
2
51 - 75
2
3
76 - 100
2
4
101 - 125
3
5
126 - 150
3
6
151 - 175
4
7
176 - 200
4
8
201 - 250
5
9
251 - 300
5
10
301 - 350
6
11
351 - 400
6
12
Over 400
7, plus 1 for each additional increment of 200 males in excess of 400
13, plus 1 for each additional increment of 100 females in excess of 400
5)The number of water closets required for primary schools and daycare centres shall be at least one for each 30 males and one for each 25 females.
6)The number of water closets required for places of worship and undertaking premises shall be at least one for each 150 persons of each sex.
7)The number of water closets required for a treatment or detention occupancy shall be determined on the basis of the special needs of the occupancy.
8)Except as permitted by Sentences (2)and (5), the number of water closets required for a care or residential occupancy shall be at least one for each 10 persons of each sex.
9)At least one water closet shall be provided for each dwelling unit.
10)Except as permitted by Sentence (2), the number of water closets required for a business and personal services occupancy shall conform to Table 3.7.2.2.-B.
Table 3.7.2.2.-B Water Closets for a Business and Personal Services Occupancy Forming Part of Sentences 3.7.2.2.(10)and (14)
Number of Persons of Each Sex
Minimum Number of Water Closets for Each Sex
1 - 25
1
26 - 50
2
Over 50
3, plus 1 for each additional increment of 50 persons of each sex in excess of 50
11)Except as permitted by Sentences (2)and (14), the number of water closets required for a mercantile occupancy shall be at least one for each 300 males and one for each 150 females.
12)Except as permitted by Sentence (2), the number of water closets required for an industrial occupancy shall conform to Table 3.7.2.2.-C.
Table 3.7.2.2.-C Water Closets for an Industrial Occupancy Forming Part of Sentence 3.7.2.2.(12)
Number of Persons of Each Sex
Minimum Number of Water Closets for Each Sex
1 - 10
1
11 - 25
2
26 - 50
3
51 - 75
4
76 - 100
5
Over 100
6, plus 1 for each additional increment of 30 persons of each sex in excess of 100
13)In a building whose floor area is more than 600 m2 and that includes one or more individual tenant spaces for a business and personal services occupancy or mercantile occupancy, water closets shall be located so that they are accessible to the public when the building is occupied.
14)The number of water closets required in a suite of mercantile occupancy whose area is not more than 500 m2 is permitted to be determined in accordance with Table 3.7.2.2.-B based solely on the total number of staff.
Note A-3.7.2.2.(1)Water Closets.
Sentence 3.7.2.2.(1) assumes that there will be a sufficient number of persons in the building to justify the provision of separate water closet facilities for both males and females. In some circumstances overall low occupant loads would not require more than one water closet for males and one water closet for females and yet the building has more than one storey. It is deemed that rooms each containing a single water closet available for both males and females would satisfy the intent of the Code. The total number of water closets must be adequate for the total number of occupants. Requirements for barrier free accessibility also need to be considered. If the entrance storey is accessible and the upper storeys are not required to be accessible, a room in the accessible storey must meet the requirements of Section 3.8. and can serve both males and females. If provided, a nonaccessible room, designed to serve both males and females, in each nonaccessible upper storey would be acceptable. Sentence 3.7.2.2.(2) permits a single water closet to serve both males and females if the total occupant load is low.
PROPOSED CHANGE
NBC20 Div.B 3.7.2.2. (first printing)
[3.7.2.2.] 3.7.2.2.Water Closets
Note A-3.7.2.2.(1)Water Closets.
Sentence 3.7.2.2.(1) assumes that there will be a sufficient number of persons in the building to justify the provision of separate water closet facilities for both males and females. In some circumstances overall low occupant loads would not require more than one water closet for males and one water closet for females and yet the building has more than one storey. It is deemed that rooms each containing a single water closet available for both males and females would satisfy the intent of the Code. The total number of water closets must be adequate for the total number of occupants. Requirements for barrier free accessibility also need to be considered. If the entrance storey is accessible and the upper storeys are not required to be accessible, a room in the accessible storey must meet the requirements of Section 3.8. and can serve both males and females. If provided, a nonaccessible room, designed to serve both males and females, in each nonaccessible upper storey would be acceptable. Sentence 3.7.2.2.(2) permits a single water closet to serve both males and females if the total occupant load is low.Although the NBC contains no implied or explicit requirements for the provision of separate gender-identified washrooms, traditional industry practice has been to provide separate washrooms. The Code only requires that certain total numbers of water closets and urinals be provided based on the expected number and demographics of building occupants. Features such as full-height partitions for the privacy of washroom users and lockable stall doors for their safety should be considered in the design of the space. Where washrooms are required to be accessible, Section 3.8. applies.
Impact analysis
This proposed change clarifies the Code’s intent through an explanatory note and is only advisory in nature.
The proposed change highlights the flexibility available to designers in designing washroom spaces. In some instances, this clarification could also facilitate AHJ approval of less traditional washroom designs, resulting in possible time, space and cost savings.
Enforcement implications
This proposed change clarifies that the existing requirements do not require washrooms to be separated according to gender. Sentence 3.7.2.2.(1) can continue to be enforced by the infrastructure currently available to enforce the Code.
Who is affected
Designers and authorities having jurisdiction will a have clearer understanding that the Codes do not require that washrooms be gender-specific.
OBJECTIVE-BASED ANALYSIS OF NEW OR CHANGED PROVISIONS
