City releases new restroom occupancy rules for tenant spaces

The city of Bellingham has issued a new building policy regarding reduced occupant loads for separate restroom requirements in existing buildings.

The policy will be in effect for all non-residential properties within Bellingham’s corporate limits.

According to the city:

“Legally established buildings that undergo a change of occupancy and that have a single rest room will not be required to install separate men’s and women’s restrooms when all of the following conditions are met:

– There is no fixed seating for more than 15 persons.
– The proposed use would not require more than one exit as determined by [International Building Code] Chapter 10.
– The space is no larger than 2,000 sq. ft.
– IBC Table 1004.1.2 will be utilized for all other occupant load based building components including total number of plumbing fixtures.
– The proponent agrees to limit the total number of persons in the space to 15 persons including customers and employees.
– The occupant load of 15 is posted on a sign in a conspicuous place readily observed from the primary entrance into the space.
– The occupant load sign will contain letters a minimum of 4″ in height with a stroke of ½” minimum. The letters will be contrasting to the background.
– The occupant load sign will contain the following verbiage  “MAXIMUM OCCUPANT LOAD OF 15 PERSONS.”
– This allowance will be revoked should it be determined that more than 15 persons at one time are utilizing the space or if the required signage is removed or obstructed.”

The city’s rationale for the new policy states:

“IBC Section 2902.2 requires separate rest room facilities for each sex when the total occupant load exceeds 15 persons. For mercantile occupancies separate facilities are required when the occupant load exceeds 100 persons.

Until the 2012 edition of the IBC, Washington State has amended IBC Chapter 29 to assign an [occupant load factor] (for required plumbing fixtures) significantly larger per person, than the generic IBC. This allowed for much larger building spaces served by a single rest room than the generic IBC would allow.

In the 2012 edition of the IBC, there are no longer modified occupant load factors. As example, under the 2009 IBC the OLF for a small dining establishment was 1 person per 30 sq. ft. In the 2012 edition of the IBC the same establishment has an OLF of 1 person per 15 sq. ft. The result is that a small dining establishment would need two rest rooms when the net area exceeds 450 sq. ft. Educational (classroom) OLF.was reduced from 100 sq. ft. per person to 20 sq. ft. per person. A 301 sq. ft. classroom would now require separate rest rooms where under previous code editions separate facilities were not required until 1,501 sq. ft.

The significant change relating to when separate rest rooms must be provided will have a major impact for existing buildings. To mitigate the impact of this code change and to help preserve the economic viability of existing building stock, provision must be made to reduce the requirement to install additional rest rooms for small spaces.

 2012 IBC Section 1004.1.2 allows the building official to approve reduced occupant loads rather than utilize the loads calculated from tabular values. Provided that adequate exiting is in place, there is no fire or life-safety concern with posting reduced occupant loads.”

For more information, contact the city’s permit center at or city building official Jim Tinner at


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