The primary intent of this requirement is that all regular washrooms be made accessible to all persons, including persons with disabilities, primarily persons who must use a wheelchair.

The exception in Clause (5)(b) recognizes situations where several washrooms may be provided on a large floor area. In such a case, not all washrooms need to be barrier-free, provided that a barrier-free washroom is available within a reasonable distance (45 m) of one that is not barrier-free and that the location of that barrier-free washroom is clearly indicated as required by Sentence 3.8.3.1.(3).

Clause 3.8.2.3.(5)(c) is intended to address “strip malls” (a shopping mall with no public corridor). Section 3.7. which requires plumbing facilities, does not address the concept of suite and could permit, for instance, a shopping mall containing only Group E occupancies (assuming the mall is more than 100 m2) to have only one washroom for each sex located in any one of the suites. It is desirable however that such washrooms be located so as to be accessible at all times, since the owner or tenant of one suite has no control over the activities of another. Such buildings may either provide public barrier-free washrooms in a central location or washrooms which can accommodate disabled persons in each suite. This arrangement relieves any one tenant from having to provide “public” washrooms. Hence, the exception for suites of less than 300 m2 is meant as a relaxation to avoid an unnecessary burden on small facilities but should not be construed as meaning that such buildings need not provide accessible washrooms.