Shower Facilities in ADA

Posted on - Thursday, May 1st, 2025
The minimum numbers of elements that are required to comply with the Guidelines of the ADA are mentioned throughout the scoping sections (Chapter 2). Sometimes they are a specific number or sometimes they are listed as a percentage. If there is not a specific number or percentage listed, it is understood that 100% of the elements or spaces must comply. In some cases there are exceptions that allow less of some elements to comply.

This newsletter will discuss showers specifically and where in the Standards states how many and if there are any exceptions to when they need to comply.

Bathing Facilities

In the ADA, showers are mentioned in scoping section 213. if a bathing facility has multiple showers or bathtubs located in the same room, you will see the minimum requirements in section 213.3.6:

213.3.6 Bathing Facilities. Where bathtubs or showers are provided, at least one bathtub complying with 607 or at least one shower complying with 608 shall be provided.

 

The drawings shown above is a multi-user shower room in a school. Only one of the shower compartments are required to comply.

If multiple shower compartments or bathtubs are provided in a multi-user shower or bathing room, then at least one shower compartment or bathtub must comply (§213.3.6), including where showers or tubs are enclosed by full-height partitions for privacy.

The photo shown above is a shower compartment located in a shower room. The compartment is created by full height walls and a door. In a multi-user bathing room, at least one must comply with the shower section (608) as well as the door section (404)

“What If a bathing facility has multiple showers or bathtubs located in separate rooms for privacy, how does scoping apply? “

If single-user bathing rooms are provided in a cluster and accessed directly from a common use corridor or hallway, then each is required to comply as a separate bathing room.

This is based on this section:

213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.

There are some exceptions pertaining to this requirement. I will list a few pertaining to showers and toilet rooms below. But keep in mind that since the requirement above lists toilet rooms and bathing rooms separately, the exceptions will be either for toilet rooms OR bathing rooms, and not for both.

EXCEPTIONS:

1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying
with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.

This exception is allowed to be taken for either a toilet room or bathing room as listed above.

2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no fewer than one toilet room for each sex complying with 603 or one unisex toilet room complyingwith 213.2.1 shall be provided.

This exception is only for toilet rooms.

3. Where multiple single user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units complying with 603 shall be identified by theInternational Symbol of Accessibility complying with 703.7.2.1.

This exception is for PORTABLE toilet or bathing units in a cluster.

4. 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.

This exception is ONLY for toilet rooms in a cluster.

Please note, that there is only one exception that reduces the BATHING ROOM requirements. Exception #3 gives exception when “portable” bathing units are clustered…then only 5% will be required to comply. These are the type that you find in an event, or construction site, and not permanent ones.

Exception #4 ONLY gives the exception to toilet rooms in a cluster, NOT bathing rooms. Therefore, if you have multiple bathing rooms located in a cluster, ALL shower rooms must comply

The drawing above shows a cluster of bathing rooms. Each one must comply.