I spoke with Jim Pecht of the U.S. Architectural and Transportation Barriers Compliance Board in March 1996 regarding ADA toilet heights for children. He said that toilets in elementary school classrooms do not have to be 17 to 19 inches high. Under the ADA's "Equivalent Facilitation" paragraph (No. 2.2), the specific requirements of the act can be bypassed if the alternative design provides "substantially equivalent or greater access". In his opinion (and mine), putting 18 inch high toilets in a first grade classroom results in worse access, not better.
There are federal standards for children's environments which were recommended in October 1995, but have not yet been approved. However, they can be applied now through the "Equivalent Facilitation" method, and they have been adopted in Massachusetts. The intended heights to the top of the toilet seats are shown in the following table.
Our recommendations for fixture heights are shown below. Our normal design practice is to use wall-hung toilets and to note on the plans "Toilet Height by Architect."
|Grade||Draft/Final Federal Standards||K & L Recommendations|
|Pre-kindergarten||11-1/2 to 12-1/2 inches||12 inches||12 inches ("baby toilet")1|
|K - 3||12 to 15 inches||15 inches||15 inches (lowest wall-hung)|
|4 - 6||15 to 17 inches||15 inches||15 inches (lowest wall-hung)|
|7-12||15 to 17 inches||15 inches||17 inches ("universal" height)|
|Adult||17 to 19 inches||15 inches||17 inches|
|Elderly||---||15 inches||15 inches2|
|1Requires confirmation for Architect, since we sometimes receive objections to these low toilets. To achieve the 12" height, a 2" lift seat is applied to the 10" high toilet.|
|2Start with this, then can adjust to 16 or 17 inches on an individual basis by applying a 2 inch or 3 inch lift seat to a 14 inches high toilet.|