Massachusetts adopted significant revisions to 248 CMR 10.00, the Uniform State Plumbing Code, effective December 8, 2023. These are significant impacts on plumbing fixture counts for men, women, and gender-neutral restrooms.

Massachusetts Plumbing Fixture Count Changes

The requirements for toilet fixtures have changed to require additional toilets in most occupancies. However, there is new guidance for specific occupancies that allow for a reduction in the number of occupants in the space to be considered when applying the new factors. Where previously, the egress occupant load was the starting point for fixture counts, under the new code:

• In “Places of Assembly”, the minimum fixture requirements are determined by the number of seats and the maximum number of employees on duty at any one time.
• In “Places of Business”, the minimum fixture requirements shall be determined by the average number of patrons visiting at any one time and the maximum number of employees on duty at any one time.

Other Key Changes: Travel Distance, Universities and Urinals

Areas where the new version of the code is less restrictive include:

• The maximum travel distance to fixtures has increased to 400 feet
• Traveling up or down one story to reach the fixtures is now permitted in most occupancies
• In university buildings, separate fixtures are no longer required for students and staff
• Urinals no longer have minimum requirements in schools and universities, they are allowed to be substituted for toilet fixtures as in most other occupancies

Gender-Neutral Restroom Requirements in Massachusetts

One of the most impactful changes is how gender-neutral restrooms can be incorporated. While they are still not required, there are different rules on how they can be provided.

• Required fixtures are still required to be calculated in accordance with the male and female fixture requirements.
• If desired, all fixtures can be provided in single-use, gender-neutral toilet rooms. Alternatively, when more than four toilets are required, single-use, gender-neutral toilets can be provided in pairs, such that for every male fixture replaced with a gender-neutral fixture a female fixture is also replaced.
• Where multi-user, gender-neutral rooms are provided a single-use, gender neutral room must also be provided within one story and 300 feet.
• Stalls in multi-user, gender-neutral rooms must have lockable partitions that extend from floor to ceiling. This does not apply to existing restrooms being converted to gender-neutral providing the existing partitions are lockable.
• The fixtures in a multi-user, gender-neutral toilet room must be calculated as serving an equal number of individuals per gender.

Potential Variances for Required Lavatories

In June 2024, the Massachusetts Board of State Examiners of Plumbers and Gas Fitters adopted a special delegation of authority intended to expedite certain variance requests involving reductions in the number of required lavatories. A variance is not automatic, and eligibility and approval depend on the circumstances of the individual project.

Massachusetts Plumbing Code Assistance

Plumbing fixture requirements can vary based on occupancy, anticipated use, project type, accessibility requirements and the interpretation of the authority having jurisdiction. Jigsaw Life Safety can assist owners, developers and design teams with fixture-count evaluations, code analysis and practical compliance strategies. Please contact us if you need assistance applying Massachusetts plumbing code requirements to your project.