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Meeting of The 2.10,19 Committee
November 30, 2004 One Ashburton Pl. Boston Mass.

1. Introduce myself, Go around the table please introduce yourself and sign the attendance sheet.

2. The purpose of this meeting is to discuss and draw some conclusions regarding regulations for the use and installation of handicapped toilet facilities as they pertain to Mass. State Plumbing Code 248 cmr, Rules and regulations of the Architectural Access Board 521 c.m.r. Mass State Building Code 780 c.m.r., and The Americans With Disabilities Act.

3. Before we open the meeting to discussion, I would like to give an explanation of why we are here and my own history and understanding of handicapped toilet facilities from one Plumbing Inspectors viewpoint.

4. 248 c.m.r. section 2.10,19 governs the use and installation of toilet facilities for all buildings.(see enclosed copy, item #1, 6 pages.) The code will dictate how many fixtures are required and what type of fixtures are required, based on the use and occupancy load of the facility. A plumbing inspector relies on this section and table #1 during plan review. And it is the plumbing inspectors responsibility to ensure compliance . (see article N.H. town probed on potty parity, item #2) As a comparison.



5. This section of the code has two faults. First it is outdated. The last time this section was revised was 1994. And back then it was revised for the same reason. More toilet facilities were needed to keep up with the population. (see article New Rules aimed at restroom parity, Boston Globe May 1994, item #3). In addition to that more modern, efficient, and accessible toilet facilities and fixtures are necessary to keep up with progress. Second is that it is difficult to read for some, making it subject to different interpretations. 

6. Committee formed. In early 2004 this committee was formed specifically to revise this section. And again as in 1994 to propose new, better regulations that are easy to read, more descriptive, and less subject to interpretations. And most importantly more, efficient, and sanitary toilet facilities for the consumer. The first question I posed to the committee was do we want to try to rewrite and repair the existing section, or scrap the whole thing and start from scratch. The consensus was to start from scratch. We started to put together a format and some language. (see draft 19.0 Minimum Requirements For Toilet Facilities And Related Plumbing Fixtures, item #4, 4 pages). 

7. Conflict. Recently there has been a conflict on the use of handicapped toilet facilities as they pertain to 248 c.m.r. section 2.10,19. More specifically handicapped toilet facilities for employees, the enforcement of dimensional requirements in 521 c.m.r., and how State codes coincide with The Americans With Disabilities Act.


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