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2010 ADA Standards for Accessible Design

ADA Toilet Paper Dispenser Height and Location

Short answer

Section 604.7 of the ADA Standards places the dispenser outlet 15 to 48 in. above the finish floor and not behind a grab bar. The dispenser's centerline goes 7 to 9 in. in front of the water closet.

Requirements at a glance

RuleRequirementSection
Outlet height15 in. minimum to 48 in. maximum above the finish floor, and not behind a grab bar
Standards text
The outlet of the dispenser shall be 15 inches (380 mm) minimum and 48 inches (1220 mm) maximum above the finish floor and shall not be located behind grab bars.
604.7
Distance in front of the water closet7 in. minimum to 9 in. maximum, measured to the centerline of the dispenser
Standards text
Toilet paper dispensers shall comply with 309.4 and shall be 7 inches (180 mm) minimum and 9 inches (230 mm) maximum in front of the water closet measured to the centerline of the dispenser.
604.7
Paper flowNo dispenser that controls delivery or blocks continuous paper flow
Standards text
Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow.
604.7
OperationOne hand, no tight grasping, pinching, or wrist twisting; 5 pounds of force maximum
Standards text
Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
309.4
Side wall grab bar heightSets where the bar sits: 33 in. minimum and 36 in. maximum, measured to the top of the gripping surface, except at water closets for children's use, where 609.4 sets a lower range
Standards text
Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface
609.4
Dispenser above the side wall grab bar (advisory)Advisory guidance: outlet 48 in. maximum, with the top of the bar's gripping surface at 33 to 36 in.
Standards text
Advisory 604.7 Dispensers. If toilet paper dispensers are installed above the side wall grab bar, the outlet of the toilet paper dispenser must be 48 inches (1220 mm) maximum above the finish floor and the top of the gripping surface of the grab bar must be 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor.
604.7
Clear space at the grab barProjecting dispenser over the bar: 12 in. of clear space minimum. Projecting dispenser under the bar or past its ends: 1½ in. minimum
Standards text
The space between the grab bar and projecting objects below and at the ends shall be 1½ inches (38 mm) minimum. The space between the grab bar and projecting objects above shall be 12 inches (305 mm) minimum.
609.3
Water closets for children's useSame 7 to 9 in. offset; outlet 14 to 19 in. above the finish floor; 1½ in. minimum clearance below the grab bar
Standards text
Toilet paper dispensers shall comply with 309.4 and shall be 7 inches (180 mm) minimum and 9 inches (230 mm) maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 14 inches (355 mm) minimum and 19 inches (485 mm) maximum above the finish floor. There shall be a clearance of 1½ inches (38 mm) minimum below the grab bar.
604.9.6
Clearance around the water closetDispensers may overlap the clearance required around the water closet
Standards text
The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
604.3.2

Source: 2010 ADA Standards for Accessible Design, U.S. Access Board. State and local codes can be stricter, and the authority having jurisdiction has the final word.

Finish floor0"12"24"36"48"60"15 to 48 in.Dispenser outletADA 604.733 to 36 in.Grab bar topADA 609.414 to 19 in.Outlet, children's useADA 604.9.6
Heights above the finish floor, drawn to scale. Dispenser outlet: 15 to 48 in. above the finish floor (ADA 604.7). Grab bar top: 33 to 36 in. above the finish floor (ADA 609.4). Outlet, children's use: 14 to 19 in. above the finish floor (ADA 604.9.6).

How to measure outlet height and offset

Section 604.7 measures height to the outlet, where the paper comes out of the dispenser. It does not measure to the top of the cover or to the mounting screws. On a large unit that feeds from the bottom, the outlet can sit well below the cover's top edge.

Take that reading from the finish floor and keep it between 15 and 48 in. For the horizontal offset, measure forward from the front of the water closet to the centerline of the dispenser. That distance must fall between 7 and 9 in., however wide the cabinet is.

Working around the side wall grab bar

Section 604.7 does not allow the dispenser behind a grab bar, so the usual choices are below the bar or above it. Below the bar, 609.3 requires 1½ in. minimum between the bar and the dispenser. Above the bar, the required gap grows to 12 in. minimum.

Advisory 604.7 gives guidance for the above-the-bar layout. It restates the 48 in. maximum for the outlet and the 33 to 36 in. range for the bar top from 609.4. Stack those limits with the 12 in. gap, and little room is left for the dispenser body. Compare the unit's drawing with the wall before you order.

Section 604.3.2 lets dispensers overlap the clearance required around the water closet, so the dispenser may sit within that space. State or local codes may set tighter rules, and the authority having jurisdiction decides.

Mistakes that fail inspection

Mounting the dispenser behind the side wall bar breaks 604.7 outright. Pushing it back toward the rear wall to save room also fails. The centerline has to land 7 to 9 in. in front of the water closet.

Another error shows up once the grab bar is installed. A dispenser tucked under the bar with less than 1½ in. of space fails 609.3. So does one mounted less than 12 in. above the bar.

The last is buying the wrong mechanism. Section 604.7 rules out dispensers that control delivery or do not allow continuous flow. Under 309.4, the dispenser's operable parts must work with one hand, without tight grasping, pinching, or twisting, at 5 pounds of force or less.

Choosing a toilet paper dispenser

Read the spec sheet for the outlet location, not just the overall height. Where the outlet sits on the unit decides how you mount it and still land between 15 and 48 in.

If the dispenser will share a wall with a grab bar, check its body height against the 609.3 gaps. Then confirm continuous paper flow and operable parts that need 5 pounds of force or less.

Toilet Tissue Dispensers buying guide and specs

ADA Toilet Paper Dispenser Height and Location: common questions

Section 604.7 sets the outlet, the point where paper exits, at 15 in. minimum and 48 in. maximum above the finish floor. The rule measures the outlet, not the top of the cabinet. The outlet also cannot be located behind a grab bar.

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