Under the 2010 ADA Standards, where single-user portable toilet units are clustered at one location, no more than 5 percent need to be accessible. California's version adds a floor of one: 5 percent, but no fewer than one, at each cluster. Accessible units must carry the International Symbol of Accessibility.
Key takeaways
- The 5 percent figure applies to each cluster of single-user portable units, not to every unit a provider owns.
- California's wording adds a floor, so any cluster needs at least one accessible unit.
- Accessible portable units must be identified with the International Symbol of Accessibility.
- The exception for clustered fixed toilet rooms does not apply to portable units.
- An accessible unit is only usable if the route from the street to it is also accessible.
- The San Francisco accessible public event checklist asks event maps to mark accessible restrooms and the route to them.
What does the 5 percent rule actually cover?
The 2010 ADA Standards, Section 213.2 Exception 3, addresses clusters of single-user portable toilet or bathing units. Where the exception applies, no more than 5 percent of the units at each cluster are required to comply with Section 603.
The exception applies when single-user portable toilet units are placed together at a single location. Think of a row of units at a festival, a construction site or a block party: the group is the cluster, and the 5 percent figure is applied to that group. The text does not describe a separate rule for each unit, so a bank of units placed together is treated as one cluster rather than several small ones. Whether a delivery looks like one cluster or two depends on where the units end up, and that placement is the thing to plan.
The percentage is a maximum for the cluster, read against the number of units in it. It is not a percentage of a provider's whole fleet, and it does not replace the other requirements that apply to the event or the site. A planner should count the units in each cluster, apply the percentage, and then apply the California floor. Those steps give the number to order. The rounding for larger clusters is not spelled out in the text this guide relies on, so the figure should be checked against the current code before an order or a permit application goes in.
Why does California require at least one accessible unit?
California's version of the text, in Chapter 11B of the 2025 California Building Code, says 5 percent, but no fewer than one, of the units at each cluster must comply with Section 11B-603. The floor means a small cluster still needs one accessible unit.
The California wording is the one to use on a California site. It differs from the federal text in a practical way: it sets a minimum. A cluster of two or three units produces less than one unit at 5 percent, so the percentage alone would require none. The California floor requires one anyway. The result is that even a small bank of portable units needs an accessible unit in it. A cluster of 20 units meets the percentage and the floor at the same single unit.
A planner organizing a small event should therefore treat the accessible unit as a requirement, not an extra. It is the minimum, and it is the one piece of the order that the cluster rule makes non-negotiable. For larger clusters, the rounding of the percentage is the open question, and the planner should confirm the number with the building official or the event permitting office before the order is placed.
What does the International Symbol of Accessibility mark?
Accessible portable units must be identified by the International Symbol of Accessibility, under Section 703.7.2.1 of the 2010 ADA Standards. The symbol tells a user which unit to use and helps staff direct people to it.
The marking is part of the requirement, not decoration. A unit that meets the accessible standard but carries no symbol leaves a user and an attendant guessing which unit is which. The symbol signals that the unit is the one set aside for accessible use at that location, and it should be visible from the route a user takes to reach it.
For a rental order, the marking is a delivery detail to confirm. Ask the provider whether the accessible unit is marked before it is placed, and check the site once the units are set. A marked unit that sits behind a stack of equipment or at the end of a blocked path does not do its job. A planner who is also writing the event map should show the accessible unit on the map as well, so that staff and visitors can find it without asking.
Is the accessible unit enough on its own?
No. An accessible unit still needs an accessible route to it. The San Francisco Mayor's Office on Disability checklist for accessible public events asks that the site have an accessible route from the street, with restrooms reachable by that route.
A unit with a wide door and a level floor is only accessible if a person using a wheelchair or walker can reach it. The route is the path from the street or the parking area, across the ground, to the unit. A curb without a ramp, a steep grade, loose gravel or a step on that route can defeat the unit, even when the unit itself meets the standard. The checklist puts the route at the center of event planning for that reason.
The checklist asks that event maps mark accessible features, including accessible restrooms. A map that shows the units but not the route is incomplete. For a planner, the sequence is to place the accessible unit first, trace the route from the street, and then check that the route is clear on the day. Routes that cross a steep grade are a common problem in San Francisco, and the guide to hillside delivery covers the access side in more detail.
Does the 50 percent exception apply to portable units?
No. Exception 4 in the same section allows 50 percent for clustered fixed toilet rooms, and it does not apply to portable units. Portable units fall under Exception 3 and its 5 percent figure.
The 2010 ADA Standards contain more than one exception for clustered toilets, and they are not interchangeable. Exception 4 is about fixed clustered single-user toilet rooms, which are built into a building. A portable unit is not a fixed room, so the 50 percent figure does not carry over. A planner who reads the wrong exception could over-order or under-order accessible units by a wide margin.
The safe reading is the narrow one. Apply the 5 percent figure, with the California floor of one, to the portable units in each cluster. Do not use the 50 percent figure to justify a smaller order, and do not treat it as a target either. If an event or site has fixed restroom rooms as well as portable units, the fixed rooms follow their own rules and the portable units follow Exception 3.
How does the rule apply to a small event?
For a small event with one cluster of two or three units, the California floor makes one accessible unit the requirement. A small order is still a cluster, and it needs an accessible unit in it.
Take a block party with two portable units on a closed residential street. The two units form one cluster. Five percent of two is less than one, so the percentage alone gives nothing, but the California floor requires one accessible unit. The order should therefore be one standard unit and one accessible unit, with the accessible unit placed on the route from the street that the planner has walked.
The same logic applies to a small construction job with clustered units. Whether a single unit counts as a cluster depends on the layout, and the planner should describe that layout in the order. A provider working from a clear description can place the units to match it, and the permit office and the event organizer can then review the same picture.
What should a planner ask the provider?
A planner should ask how many units are accessible, how each cluster is laid out, how the symbol is applied, and how the route will be cleared. The answers should match the cluster rule before the delivery is scheduled.
Start with the count. Ask how many units are in each cluster and how many of them are accessible, then confirm that the number meets the 5 percent figure and the California floor. A bank of twenty units needs one accessible unit under the percentage alone, and the floor does not add to that. Ask also whether the accessible unit will carry the International Symbol of Accessibility before it is placed.
Then ask about the route. Where will the accessible unit sit, how will it be reached from the street, and who checks the ground before the day? The provider does not control the route, but the planner does, and the planner should walk it. A unit placed on the far side of an uncut curb is out of reach for a wheelchair user, however well it is marked. Call (888) 351-0294 with the site layout before the order is fixed.
Frequently asked questions
What is the minimum number of accessible portable toilets in California?
For each cluster of single-user portable toilet units, California requires 5 percent of the units to be accessible, but no fewer than one. That makes one accessible unit the minimum for any cluster. Larger clusters use the 5 percent figure, and the rounding for them should be confirmed with the building official. The minimum applies per cluster, not across a whole rental order.
Does every portable toilet need the International Symbol of Accessibility?
The symbol is required on the accessible units, under Section 703.7.2.1 of the 2010 ADA Standards. It identifies the units that meet the accessible standard. A standard unit does not carry the symbol under that section, although a planner may label units for clarity on a site map.
Is the accessible unit enough if the route to it is steep?
The unit can meet the standard and still be unusable if the route to it is not accessible. The San Francisco checklist asks for an accessible route from the street, with restrooms reachable by that route. A steep grade, a stair or an uncut curb on the way can defeat the unit. Walk the route before the day of the event.
Does the 50 percent exception apply to portable toilets?
No. Exception 4 of Section 213.2 covers fixed clustered single-user toilet rooms, not portable units. Portable units fall under Exception 3, which sets the 5 percent figure. The California floor of one accessible unit applies to each cluster on top of that figure.
Does the accessibility rule come from the federal ADA?
The 2010 ADA Standards are the federal text, and the California version in Chapter 11B of the building code adds the floor of one accessible unit. A California site should use the California wording. The planner should check the current code before placing an order, because the text is reproduced in several places and the wording should match the version in force.
Does a block party need an accessible portable toilet?
A block party with a cluster of portable units needs one accessible unit under the California floor. The cluster rule applies whether the event is a festival or a small neighborhood gathering. The accessible unit should be placed on a route from the street that the planner has walked before the day.
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This guide is general information for San Francisco County homeowners, not a substitute for an on-site inspection. Prices are estimates. See our disclaimer.