Private Bathrooms

Posted on - Wednesday, July 1st, 2015

There is a misconception that a private bathroom is exempted from having to comply with the 2010 ADA Guidelines and the 2012 TAS.  In reality, even private bathrooms must comply, although there are some exceptions they can take. In order to take the exceptions, a bathroom is deemed “private” if  the bathroom is accessed from a private office and not for public or common use.  This newsletter will discuss what items are required to be provided at private bathrooms, and which one’s can be left out. There is a summary from TDLR on TM 2013-19 which we will discuss in detail.


At a private bathroom that is accessed through a private office and not for common use, the toilets must comply with all the requirements except for:

  1. The height of the toilet does not have to be 17″-19″ a.f.f.  It can be higher or lower than the minimum required heights.
  2. Grab bars are not required to be installed, but blocking must be provided within the wall for future installation
  3. In the Toilet and Bathing rooms the door shall swing into the clear floor space of the fixtures in a private office

So a private toilet must still have the clearances required at the floor area distance from the side wall, flush control and toilet paper dispenser must comply with 604


The photo above shows the proper floor clearance, but the flush control and the toilet paper dispenser were not correctly located 


The toilet in this photo does not have the proper floor clearance per 604 nor is the toilet paper dispenser mounted at the proper location


At a private bathroom accessed from a private office and not for public use must have a sink that complies with everything in section 606 except:

  1. The sink does not have to have a knee space complying with 306 for forward approach.  A parallel approach is allowed to be provided.
  2. The height of the sink does not have to be a 34″ a.f.f. maximum.  It can be higher or lower than what the Standards require.

The sink is required to have the proper faucet mechanism, the mirror at the correct height, and floor area for parallel approach.


Because a private bathroom does not require a knee space at the sink, a pedestal sink can be used.  The mirror on the other hand must be mounted at 40″ a.f.f. to the bottom of the reflective surface.

Showers and Tubs

At a private bathroom accessed by a private office and not for public or common use, the showers and tubs have to comply with all the requirements of section 607 and 608 except for:

  1.  Grab bars do not have to be installed, but blocking within the walls for future installation must be provided.

Otherwise, a shower must have the controls installed at the proper reach range, a hand held shower unit must be provided, the threshold at the entry must not be higher than 1/2″, the size of the shower must comply, and at a transfer shower a seat must also be provided.


This shower doesn’t have a seat or a handheld shower unit.  In addition there is a door which doesn’t have clearance on the interior of the shower 

Upcoming Continuing Education Opportunities


Tuesday July 21st from 3:00-4:00 CST “Understanding the 2010 ADA Standards” Provided by Green CE

Thursday July 23rd

Sit in a wheelchair for a Day!  Join several of your fellow architects in Dallas and experience what a person who uses a wheelchair experiences.  For more information contact Marcela Rhoads at

Friday July 24th ALL DAY!  Join Us!!!

Marking the 25th anniversary of the ADA, July 24th will be ADA Awareness day in Dallas Texas.  The AIA Dallas’s Codes and Standards committee is planning a day full of great programs.  Stay tuned.  If you want to be a sponsor, let me know.


Thank you to our Sponsors: Andres Construction, Access by Design and

Abadi Accessibility

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley. 


 They are available for sale now. (also available as an e-book)
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
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