Number of Required Accessible Units in Dormitory Suites

A major factor that affects the design of dormitory buildings is the number of required accessible units. Both the IBC and the ADA require a certain number of accessible units based on the total number of dwelling units or sleeping units. Traditional dormitories were designed with multiple sleeping rooms accessed from a common corridor and group bathrooms that are shared by the entire floor. Determining the minimum number of accessible rooms for this type of configuration is simply based on the number of sleeping units. However, the design of dormitory buildings has changed in the past 10 to 15 years to include many more suite or apartment style units. These units are configured with multiple bedrooms having dedicated bathrooms, kitchens or both within the suite or apartment. Similar to the evolution of design, the code has also evolved, which can be costly to projects if missed.

Section 1107.6.2.3 of the 2015 IBC was changed to address suite and apartment style units. The following sentence was added at the end of the section:

Where the sleeping units are grouped into suites, only one sleeping unit in each suite shall be permitted to count towards the number of required Accessible units.

 The commentary for this section states the following:

The new style of dormitory living is groups of bedrooms that share a common living space, sometimes with a kitchen or kitchenette. If these are counted as dwelling units instead of sleeping units, the number of Accessible rooms available may be less, or multiple bedrooms in the same suite would be interpreted to all be Accessible units. Administratively, when housing students, the universities still treat this style of units as the old-style dorm rooms down a long hallway. The last sentence is intended to make clear that for the purpose of determining the number of Accessible units, the bedrooms in any congregate residence must be counted separately. In a suite configuration, only one of the sleeping units can be counted as part of the required number of Accessible units.

Though not specifically stated in the 2015 IBC, the commentary states that each bedroom in a suite or apartment should be counted separately when determining the minimum number of required accessible bedrooms. Also, the code language only allows one bedroom in each suite/apartment to count as an accessible unit. The language in the 2015 IBC is specific to sleeping units, which can be interpreted in different ways if the dormitories are dwelling units (with kitchens and bathrooms). To clarify this the 2018 IBC was revised as follows:

Bedrooms within congregate living facilities, dormitories, sororities, fraternities and boarding houses shall be counted as sleeping units for the purpose of determining the number of units. Where the bedrooms are grouped into dwelling or sleeping units, only one bedroom in each dwelling or sleeping unit shall be permitted to count toward the number of required Accessible units (2018 IBC 1007.6.2.3).

Though it is open to interpretation under the 2015 IBC, it is clear under the 2018 IBC that (1) each bedroom in a suite/apartment is counted separately when determining the minimum number of required accessible units and (2) only one bedroom in each accessible suite/apartment can count towards the minimum number of required accessible units. Since most suites/apartments tends to have 4 to 6 bedrooms, this can result in having many more accessible suites/apartments than most design professionals would plan under legacy codes.