Minimum Plumbing Requirments - 2010 CPC 412.3

Hello BCDG,

My firm is working with a ±1,600 sf tenant in a shopping center. It is a M Occupancy. We have desgned the space with a single-accomodation toilet room per 2010 CPC 412.3 exception #2. Unfortunately, our local BO interpretation is that we are required two single-accomodation toilet rooms. They say that since we don't meet the requirements for exception #3 (the space is > 1,500sf of merchantile space) exception #2 does not apply. The BO believes that exception #2 is only meant for uses such as warehouses.

The way I see it is that our space has 8 occupants (1600÷200=8) and we should fall under exception #2. Aren't these exceptions put into place to be used in situations for this? Does anyone have any additional arguments or publications from other jurisdictions to prove that we can use any or all of the exceptions listed under CPC 412.3 (or any similar exceptions in the code) that will help my BO see that they are interpreting this incorectly?

Thanks for your help!

Greg Frank
Architect
NCARB, LEED AP
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