170109 MAD (Alternative Design Proposal) (2).pdf
ALTERNATIVE DESIGN PROPOSAL
9 January 2016
Leif Bjorback, Building Official
City of Edmonds Development Services Department
121 5th Avenue North
Edmonds, WA 98020
t: 425-771-0220
e: leif.bjorback@edmondswa.gov
To: Leif Bjorback
From: Andy Drissell
Project: Madrona School Replacement, Edmonds School District
RE: Alternative Design Proposal, Inclusive Toilet Facilities
Attachments: “Separate Facilities - OSSC/29/#2,” City of Portland (BDS)
Our design team is looking to provide gender inclusive toilet facilities for the Madrona School
Replacement project in the Edmonds School District. This process has involved students, parents, and staff
members from the district and strives to comply with the May 2016 United States “Department of Justice
and Department of Education Joint Guidance on Civil Rights of Transgender Students” and the
Washington Law Against Discrimination (RCW 49.60).
As discussed at our meeting on December 2, 2016, and in subsequent emails, we understand that our
proposed interpretation of the 2015 International Building Code (IBC) and design strategy lies outside of
the City of Edmonds conventional building code approach for providing traditional men’s and women’s
facilities. As such, our team would like to put forth this Alternative Design Proposal according to IBC
section 104.11:
104.11 Alternative materials, design and methods of construction and equipment.
The provisions of this code are not intended to prevent the installation of any material or to
prohibit any design or method of construction not specifically prescribed by this code, provided
that any such alternative has been approved. An alternative material, design or method of
construction shall be approved where the building official finds that the proposed design is
satisfactory and complies with the intent of the provisions of this code, and that the material,
method or work offered is, for the purpose intended, not less than the equivalent of that
prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety.
Where the alternative material, design or method of construction is not approved, the building
official shall respond in writing, stating the reasons why the alternative was not approved.
We have worked to design toilet facilities that are safe, secure, and inclusive throughout the educational
facility. The following narrative describes our interpretation of the IBC and strategy for compliance.
IBC Section [P] 2902.2 states, “Where plumbing fixtures are required, separate facilities shall be provided
for each sex.” As “separate facilities” are not explicitly defined in the IBC, we would like to reference the
attached interpretation by the City of Portland Bureau of Development Services (BDS), Separate Facilities –
OSSC/29/#2. They determined that facilities meeting the following requirements may be considered to be
separate facilities for the purposes of this code section (See FIGURE 1 and FIGURE 2):
A. Full Height Walls and Doors. Each water closet must be enclosed by a 6’-8” minimum
door that fills the door frame, and floor to ceiling partition walls.
B. Overlapping Jambs. Each water closet must have a doorjamb that overlaps the door in the
closed position;
C. Occupied Indicators. Each water closet must have locking hardware that functions with
an indicator showing whether it is occupied or vacant;
D. Ventilation. Each water closet must have separate ventilation.
E. Lavatories. The lavatory(s) may be located within the water closet or outside of the water
closets in a cluster setting; and
F. Other Requirements. All other code requirements, including but not limited to, minimum
number of fixtures required, accessibility, family or assisted-use facilities, and signage must
be met.
FIGURE 1 FIGURE 2
(EXCERPTS FROM CITY OF PORTLAND BDS
“SEPARATE FACILITIES – OSCC/29/#2”)
In line with the City of Portland BDS interpretation of “separate facilities” and FIGURE 1, we have
designed all toilet facilities for the Madrona School Replacement project as single occupant water closets
detailed to comply with items A – F listed above.
Some of these toilet facilities are designed as Family / Assisted Use rooms and include a lavatory (see
FIGURE 3), while others are clustered around shared sink locations (see FIGURE 4). Although gender is
factored in for fixture count and occupancy calculations (see TABLE 1 and TABLE 2 below), the facilities
would be and would be signed generically as “TOILET” or “WC”.
Providing clear signage that does not assign a specific gender to the water closets or sinks allows all
people, including transgender people, the opportunity to use the facilities without choosing a gendered
restroom. By designing to this standard across the entire school, “separate facilities” are equitably
provided for each gender while also addressing issues of privacy and safety.
TABLE 1
Toilet Room 116 (FIGURE 5) is situated adjacent to the Gymnasium and Commons (Cafeteria) areas, two
areas that are intended for assembly use during and after school hours. Plumbing fixture counts have been
calculated for this assembly area per Table 2902.1 for type A-3 occupancy (see TABLE 2).
We would like to note that we are defining Toilet Room 116 as a cluster of water closets (i.e. toilet
facilities per “Separate Facilities – OSSC/29/#2”) within a single toilet room, and not as a cluster of
separate toilet rooms. As noted above, the proposed design in for Toilet Room 116 (FIGURE 5) does not
assign a specific gender to the water closets or sinks thereby allowing all people, including transgender
people, the opportunity to use the facilities without choosing a gendered restroom.
Toilet Room 116 is paired with Toilet Rooms 118A-118C (FIGURE 5), which are family / assisted-use,
single occupancy toilet rooms. These provide an additional option for individuals who need family
assistance, for individuals who require a private lavatory for religious reasons, and for those who may not
be comfortable in the clustered WC location.
SCHOOL, GROUP E
OCCUPANCY
79,525 sf Gross Area
796 Occupancy
Sex Occupant Load Required Fixtures
Fixtures
Provided
M 796 / 2 = 398 398 / 35 = 12 12 toilets 22 toilets
398 / 85 = 5 5 lavs 22 lavs
F 796 / 2 = 398 398 / 25 = 16 16 toilets 28 toilets
398 / 50 = 8 8 lavs 23 lavs
Notes:
1. Fixtures per occupant per WAC 51-50-2900 Emergency Rule amending WSR 13-04-067, effective 07.01.13.
2. Increased Gym / Commons / Platform / Risers occupancy of 1,538 per 1004.2 is an infrequent use and not
simultaneous with regular E occupancy of remainder of building. (See TABLE 2)
3. Per 2902.5.1, Occupancy of 796 requires 3 Drinking Fountains, 11 provided.
TABLE 2
Accessible water closets have been provided per IBC Section 1109.2.2: “Where water closet
compartments are provided in a toilet room or bathing room, at least 5 percent of the total number of
compartments shall be wheelchair accessible. Where the combined total water closet compartments and
urinals provided in a toilet room or bathing room is six or more, at least 5 percent of the total number of
compartments shall be ambulatory accessible, provided in addition to the wheelchair accessible
compartment.”
TABLE 3
Type
WATER CLOSETS
Toilet Rooms 118A-118C
(Family / Assisted Use)
Toilet Room 116
(Clustered Water Closets)
Male Female Male Female
Standard 4 8
Accessible
(wheelchair) 1 2 1 1
Accessible
(ambulatory) 1 1
Total Water Closets
at Location 3 16
Percent Accessible
(wheelchair) 100% 12.5%
Percent Accessible
(ambulatory) 12.5%
Regarding section 2902.1.1.2 of the 2015 WSBC stating “[for] men's facilities serving 26 or more persons,
not less than one urinal shall be provided,” we would propose that as each water closet is defined as a
“separate facility” each serving a single occupant, the requirement for “not less than one urinal” would
not apply to Toilet Room 116.
Our team appreciates your review and comment on the proposed Alternative Design Proposal and our
interpretation of the 2015 IBC. Please let us know if you have any questions, comments, and/or
suggestions that may assist in the design of our toilet facilities for the Madrona School Replacement.
Scenario of increased occupancy Gym and Commons Event (See sheet G-102)
(INFREQUENT USE)
GYM / COMMONS - Concentrated
10,122 sf Gross Area (7 Net)
1,446 Occupancy
PLATFORM / RISERS
1,364 sf Gross Area (15 Net)
92 Occupancy
1,538 Occupancy (Total)
Sex Occupant Load Required Fixtures
Fixtures
Provided
M 1,538 / 2 = 769 769 / 125 = 7 7 toilets 7 toilets
769 / 200 = 4 4 lavs 5 lavs
F 1,538 / 2 = 769 769 / 65 = 12 12 toilets 12 toilets
769 / 200 = 4 4 lavs 6 lavs