Minnesota Department of Labor and Industry Orange bar
Minnesota Department of Labor and Industry

Opinion: Existing toilet room accessibility




Existing toilet room accessibility 


1994 UBC Appendix Section 1111.1.2 (yr., title, section) 

Submitted By:

City of Minneapolis

Approved By:

Thomas R. Joachim, State Building Official 

Issue Date: 

October 14, 1996 


Two story motel having all required accessible rooms, public amenities and second floor like guestrooms located on first floor. Is an accessible route (via elevator or ramp) required to the second floor of this two-story motel? 


Although the literal reading would say so, our answer is no. This is based largely on an interpretation received by ICBO which states,

It is not the intent of the UBC to require an accessible route to an inaccessible floor, [of transient type housing] if all of the facilities are provided on the first story and there are no features on the second story which are not common to the first. (text in brackets added by division for context) 

Division comments:

When considering UBC Appendix Section 1111.1.2 in regard to existing restroom accessibility, shall restrooms be required to be updated (20% of cost maximum) to five (5) foot wide stall etc. if they met previous state accessibility code?  

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