Code Pathways to Non-ADA Unisex Restrooms

April 4, 2022
It’s a common belief that every single-occupancy unisex restroom must be ADA compliant. However, the building code does not always require this, and in this article, we’ll explore just that.
ADA and non-ADA restroom cluster
First, let’s look at what the 2018 North Carolina Building Code (NCBC) has to say about Plumbing Systems:


Per 2902.2 Separate facilities: Where plumbing fixtures are required, separate facilities shall be provided for each sex.


However, per Exception 5: Where the code requires only one toilet facility for each sex, two unisex facilities may be substituted for separate sex facilities.


What does this mean to architects? It’s as straightforward as it sounds. Two unisex restrooms can substitute for one of each men’s and women’s.


Additionally, we look to Accessibility in the NCBC. This is based on ANSI A117.1, a similar version of the 2010 ADA Standards for Accessible Design. Per 1109.2 Toilet and bathing facilities:


“Each toilet room and bathing room shall be accessible. Where a floor level is not required to be connected by an accessible route, the only toilet rooms or bathing rooms provided within the facility shall not be located on the inaccessible floor. Except as provided for in Sections 1109.2.2 and 1109.2.3, at least one of each type of fixture, element, control or dispenser in each accessible toilet room and bathing room shall be accessible.”


Exception 3. Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50 percent but not less than one room for each use at each cluster shall be accessible.


Here, we find an exception requiring only 50% of clustered single-use restrooms to be ADA. When these sections are utilized together, it allows for a design to utilize a clustered group of unisex toilet rooms, only half of those being ADA accessible. See Figures 1 and 2.

Layout of ADA and non-ADA restroom cluster
Understanding these sections of the building code, and how to properly apply them, works to everyone’s advantage:


  • Space-saving – An accessible restroom must be of a certain physical size. In Figure 2 above, it’s 20 square feet larger than a standard (non-ADA compliant) room. Each and every square foot is valuable to an owner.
  • Cost-saving – Accessible toilets and sinks cost more to buy and are often more limited in terms of styles. Grab bars are a full extra requirement.


If you have specific questions about accessibility and restroom compliance, give us a call at 919-341-4247 or send us an email at