Interpretation #: CEB-2019-06-2012 IPC-202

Building or Fire Safety Law Interpreted

675 IAC 16-1.4 Indiana Plumbing Code, 2012 Edition; Section 202 GENERAL DEFINITIONS; PUBLIC OR PUBLIC UTILIZATION: In the classification of plumbing fixtures, "public" applies to fixtures in general toilet rooms of schools, gymnasiums, hotels, airports, bus and railroad stations, public buildings, bars, public comfort stations, office buildings, stadiums, stores, restaurants, and other installations where a number of fixtures are installed so that their utilization is similarly unrestricted.

Issue

The local building official has issued a violation order for a school in which a number of small-scale multiple-fixture toilet rooms are shared by pairs of classrooms, because those toilet rooms do not contain the required lavatories. Rather, the lavatories are provided in the adjoining classrooms. The building official maintains this is a violation of IPC 405.3.2, which states that in employee and public toilet rooms, the required lavatories must be located in the same room as the required water closet. The school, however, maintains that these toilet rooms do not meet the IPC's definition of "public" and therefore fall outside the jurisdiction of 405.3.2. They state that not only are these facilities not for the general school population, but that their use will always be under supervision, both of which they argue are forms of restricted utilization.

Interpretation of the State Building Commissioner

For the purposes of interpretation and application of the Indiana Plumbing Code, the toilet rooms in question are considered public.

Rationale

In addition to the specific listed fixture installations that the IPC definition considers "public", the definition also provides an additional specific design criterion which places other installations in the "public" category. That criterion is contained in the final phrase, "where a number of fixtures are installed so that their utilization is similarly unrestricted".

That phrase is describing a singular condition – one in which the state of unrestricted access is created by the number of fixtures present. "Unrestricted access", for the purposes of categorizing toilet facilities under this code, is not a function of whether the rooms are immediately available to the general school population, or whether a figure of authority grants or denies free and unsupervised use of the space. It describes a condition in which the number of fixtures in the space effectively allows or prevents simultaneous use by more than one individual or family. If only one individual or family can be accommodated at a given time, the room is considered private. If it can accommodate more than one, it is considered public.