Installation Height of Accessible Menstrual Product Dispensers
Description:
This proposed change requires that menstrual product dispensers, where provided, be mounted in an accessible location so that they may be reached from a seated posture.
Related Code Change Request(s):
CCR 1441
Related Proposed Change(s):
PCF 2029
Problem
Lack of access to menstrual products can lead to persons having to miss work, school or social events, and can lead to health consequences. In some buildings and facilities, menstrual products dispensers are installed in washrooms alongside dispensers for soap, towels and other products. However, unlike soap dispensers and other equipment, the NBC does not regulate the design and installation of menstrual product dispensers (where they are provided) with respect to accessibility. This lack of accessibility requirements can cause problems for persons with limited mobility who menstruate, especially those who use wheeled mobility aids, because they may not be able to reach menstrual product dispensers if they are mounted too low or too high.
Justification
This proposed change would introduce new requirements for the installation location of wall-mounted menstrual product dispensers where they are provided in barrier-free washrooms so that they can be reached by people seated in wheeled mobility aids.
By introducing accessibility requirements for the installation position of menstrual product dispensers, the proposed change would help to limit the probability that people who are seated in wheeled mobility aids will be unable to access menstrual products.
Similar to accessibility requirements for toilet paper and soap dispensers, the proposed change addresses the installation location of menstrual product dispensers where they are provided but does not address operational issues related to the provision or stocking of dispensers.
PROPOSED CHANGE
[3.8.2.8.] 3.8.2.8.Plumbing Facilities
[1] 1)Except as permitted by Sentence (3), at each location where washrooms are provided in a storey to which a barrier-free path of travel is required in accordance with Article 3.8.2.3., at least one universal washroom complying with Subsection 3.8.3. shall be provided. (See Note A-3.8.2.8.(1) to (4)PROPOSED CHANGE A-3.8.2.8.(1) to (4).)
[2] 2)Except as permitted by Sentence (3), where more than two water closets or a combination of more than one water closet and one urinal are provided in a washroom located in a storey to which a barrier-free path of travel is required in accordance with Article 3.8.2.3., at least one water-closet stall shall be barrier-free in accordance with Subsection 3.8.3. (See Note A-3.8.2.8.(1) to (4)PROPOSED CHANGE A-3.8.2.8.(1) to (4).)
[3] 3)Washrooms located within a suite of residential occupancy or a suite of care occupancy need not conform to the requirements of Sentence (1)or (2). (See Note A-3.8.2.8.(1) to (4)PROPOSED CHANGE A-3.8.2.8.(1) to (4).)
[4] 4)In a building in which water closets are required in accordance with Subsection 3.7.2., at least one barrier-free water closet shall be provided in the entrance storey, unless
[a] a)a barrier-free path of travel is provided to barrier-free water closets elsewhere in the building, or
[b] b)the water closets required by Subsection 3.7.2. are for dwelling units only.
(See Note A-3.8.2.8.(1) to (4)PROPOSED CHANGE A-3.8.2.8.(1) to (4).)
[5] 5)At least one water-closet stall or enclosure in a washroom required to be barrier-free shall comply with Subsection 3.8.3.
[6] 6)Where urinals are provided in a barrier-free washroom, at least one urinal for persons with limited mobility conforming to Subsection 3.8.3. shall be provided for every 10 urinals.
[7] 7)Where water-closet stalls are provided in a barrier-free washroom, at least one stall for persons with limited mobility conforming to Subsection 3.8.3. shall be provided for every 10 stalls.
[8] 8)A barrier-free washroom shall be provided with a lavatory that complies with Subsection 3.8.3.
[9] 9)Where mirrors are provided in a barrier-free washroom, at least one mirror shall comply with Subsection 3.8.3.
[10] --)Where a menstrual product dispenser is provided in a barrier-free washroom, it shall comply with Subsection 3.8.3.
[11] 10)At each location where one or more drinking fountains are provided, at least one of them shall comply with Subsection 3.8.3.
[12] 11)At each location where one or more water-bottle filling stations are provided, at least one of them shall comply with Subsection 3.8.3.
[13] 12)Except within a suite of care occupancy or a suite of residential occupancy, where showers are provided in a building, at least one shower stall in each group of showers shall comply with Subsection 3.8.3.
[14] 13)At each location where a showering facility is provided for use by the general public or customers, or as part of a common-use area for employees, at least one universal dressing and shower room conforming to Subsection 3.8.3. shall be provided. (See Note A-3.8.2.8.(13)PROPOSED CHANGE A-3.8.2.8.(13).)
[15] 14)Where a bathtub is installed in a suite of residential occupancy required to be barrier-free, it shall comply with Subsection 3.8.3.
[16] 15)In buildings containing Group A, Group B, Division 2 or Group E major occupancies where at least one of these major occupancies has an occupant load of more than 500, at least one universal washroom on the storey on which the main barrier-free entrance to the building is located shall incorporate an accessible change space conforming to Subsection 3.8.3. (See Note A-3.8.2.8.(15)PROPOSED CHANGE A-3.8.2.8.(15).)
[3.8.3.16.] 3.8.3.16.Lavatories,and Mirrors and Other Washroom Amenities
[1] 1)Lavatories required by Sentence 3.8.2.8.(8) shall
[a] a)be equipped with faucets complying with Sentence 3.7.2.3.(4),
[b] b)be located so that the distance between the centre line of the lavatory and any side wall is not less than 460 mm,
[c] c)have a clear floor space in front of the lavatory that is at least
[i] i)800 mm wide, centred on the lavatory, and
[ii] ii)1 350 mm long, of which no more than 430 mm is beneath the lavatory,
[d] d)have a rim height not more than 865 mm above the floor,
[e] e)have a clearance beneath the lavatory not less than
[i] i)800 mm wide, centred on the lavatory,
[ii] ii)735 mm high at the front edge,
[iii] iii)685 mm high at a point 200 mm back from the front edge, and
[iv] iv)230 mm high over the distance from a point 280 mm to a point 430 mm back from the front edge,(see Note A-3.8.3.16.(1)(e)PROPOSED CHANGE A-3.8.3.16.(1)(e))
[f] f)have insulated water supply and drain pipes where these pipes are exposed (see Note A-3.8.3.16.(1)(f)PROPOSED CHANGE A-3.8.3.16.(1)(f)),
[g] g)have a soap dispenser that
[i] i)is automatic, or
[ii] ii)complies with Clause 3.8.3.8.(1)(b) and is located not more than 1 100 mm above the floor, within 500 mm from the front of the lavatory (see Note A-3.8.3.16.(1)(g)PROPOSED CHANGE A-3.8.3.16.(1)(g)), and
[h] h)have a towel dispenser or other hand-drying equipment located close to the lavatory, not more than 1 200 mm above the floor in an area that is accessible to persons in wheelchairs.
[2] 2)Mirrors required by Sentence 3.8.2.8.(9) shall be
[a] a)mounted with their bottom edge not more than 1 000 mm above the floor, or
[b] b)fixed in an inclined position so as to be usable by a person in a wheelchair.
[3] --)The menstrual product dispenser referred to in Sentence 3.8.2.8.(10)-2025 shall be mounted such that its controls and dispensing components are located
[a] --)in accordance with Clause 3.8.3.8.(1)(a), except that the dispenser shall not be mounted less than 600 mm above the floor, or
[b] --)on the side wall closest to the barrier-free water closet, in accordance with Subclauses 3.8.3.12.(1)(i)(i) and (i)(ii).
Impact analysis
Financial Impact
The impact of the proposed change would vary for different buildings, because the change does not mandate that menstrual product dispensers be provided. Rather, it specifies that if these dispensers are provided, they must be installed such that they can be used equally by all people who may need them. Some building owners or operators may decide to provide alternatives to commercial dispensers, depending on their needs (e.g., a basket of products on the lavatory counter); in these cases, the proposed change would have no cost implications.
The installation location requirements are not expected to affect the cost of procuring dispensers. Designers would need to consider the location of menstrual product dispensers in relation to other equipment.
The proposed restrictions on the installation location of menstrual product dispensers are not expected to impact manufacturers, because they do not introduce new requirements for product design.
Accessible Usage Impact
The proposed change is expected to improve the accessibility of menstrual product dispensers for persons with mobility disabilities. Approximately 1% of Canadian adults regularly use wheeled mobility aids (Smith et al., 2016). While data on the distribution of disability by sex are not available from the most recent Canadian Survey on Disability, earlier surveys indicate that female adults are 25% more likely than male adults to have disabilities related to mobility (Statistics Canada, 2012). While disabilities are less common among people of menstruating age (12 to 56 years1) than among people over 65 (Statistics Canada, 2017), they affect people of all ages, and anyone who may need menstrual products should be able to access them when they are provided in a building. The consequences of being unable to do so can include missing school, work or other activities.
1 In Canada, the median age of onset of menstruation is approximately 12 years (Al-Sahab et al., 2010), while the median age of menopause is approximately 50 years (Costanian et al., 2018). However, menstruation is common up to approximately 56 years, the age at which approximately 90% of females in Canada have experienced menopause (Costanian et al., 2018).
References
Al-Sahab, B., Ardern, C. I., Hamadeh, M. J., and Tamim, H. (2010). Age at menarche in Canada: results from the National Longitudinal Survey of Children and Youth. BMC public health, 10, 1-8.
Costanian, C., McCague, H., and Tamim, H. (2018). Age at natural menopause and its associated factors in Canada: Cross-sectional analyses from the Canadian Longitudinal Study on Aging. Menopause, 25(3), 265-272.
Smith, E., Giesbrecht, E., Mortenson, W., Miller, W. (2016). Prevalence of wheelchair and scooter use among community-dwelling Canadians. Physical Therapy96, 1135-42.
The proposed change could be enforced in the same way as accessibility requirements for other washroom features such as soap dispensers and lavatory controls, i.e., through visual inspection and basic measurement tools.
Who is affected
Building occupants, particularly those who use wheeled mobility aids, would be able to access menstrual product dispensers.
Building owners would need to decide if the building’s washrooms should be equipped with menstrual product dispensers.
Designers would need to ensure dispensers are mounted in appropriate locations.
Authorities having jurisdiction would need to ensure that dispensers comply with the mounting requirements.
OBJECTIVE-BASED ANALYSIS OF NEW OR CHANGED PROVISIONS
